Search Results for "Section 148 Income Tax Act"

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Search Results for "Section 148 Income Tax Act"

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High Court

Bombay High Court Allows Petition in Income Tax Reassessment Case Due to Change of Opinion. Reassessment under Section 148 of the Income Tax Act, 1961 cannot be based on a mere change of opinion on the same facts already examined.

26 Sep 2023

The petitioner, Knight Riders Sports Pvt. Ltd., which operates the Kolkata Knight Riders team in the Indian Premier League, challenged a notice dated ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 for Lack of Fresh Material — Audit Objection Cannot Form Reason to Believe Income Escaped Assessment. The court held that a notice to reopen assessment based solely on an audit objection, without independent application of mind by the Assessing Officer, is invalid as it amounts to a change of opinion.

1 Feb 2013

The petitioner, NTUC Income Insurance Co-operative Ltd., a company incorporated in Singapore and registered with SEBI as a Foreign Institutional Inves...

High Court

Gujarat High Court Quashes Notice Under Section 153A for Assessment Year 2011-12 in Search Case — Notice Issued Beyond Six-Year Limit Invalid. The Court held that the notice under Section 153A for AY 2011-12 was barred by limitation as the search was conducted on 08.10.2020 and the six-year period preceding the assessment year of search (2021-22) would cover AYs 2015-16 to 2020-21, not AY 2011-12.

4 Feb 2026

The petitioner, an individual with agricultural income, rental income, and partnership income from M/s. Popular Developer, was subjected to a search u...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Reasonable Belief and Change of Opinion. Reassessment Beyond Four Years Invalid Without Proof of Failure to Disclose Material Facts.

30 Jun 2023

The petitioner, Vedanta Limited (formerly Sterlite Opportunities and Ventures Limited), challenged a notice dated 28 March 2008 issued under Section 1...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Change of Opinion on Deduction Under Section 10AA of Income Tax Act, 1961 is Invalid.

10 Jan 2022

The petitioner, Oracle Financial Services Software Limited, is a company engaged in providing information technology solutions to banks and financial ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income-tax Act for Lack of Fresh Material — Reopening Based on Mere Change of Opinion Not Permissible. The Court held that where the Assessing Officer had already examined the issue of sundry creditors during original scrutiny assessment under Section 143(3), reopening on the same ground without fresh tangible information is invalid.

15 Feb 2023

The Petitioner, Punia Capital Pvt. Ltd., challenged the validity of a notice under Section 148 of the Income-tax Act, 1961 and the consequent reopenin...

High Court

Bombay High Court Quashes Reassessment Notice and Assessment Order in Income Tax Case Due to Lack of Fresh Material. Reassessment under Section 147/148 of Income Tax Act, 1961 invalid as based on same material already considered in original assessment under Section 143(3).

20 Feb 2023

The petitioner, Pushpa Nahata, challenged a notice under section 148 of the Income Tax Act, 1961 dated 30 March 2022 and an assessment order dated 22 ...

High Court

Bombay High Court Quashes Reopening of Assessments Under Section 148 for Lack of Fresh Material — Deduction Under Section 80IB Allowed After Scrutiny in Original Assessment. Reopening Based on Same Facts Already Examined Under Section 143(3) Amounts to Change of Opinion and Is Invalid.

8 Feb 2010

The petitioner, Purity Techtextile Private Limited, challenged the reopening of its income tax assessments for Assessment Years 2003-2004 and 2004-200...

High Court

Bombay High Court Quashes Reopening Notice in Income Tax Case Due to Lack of Fresh Material — Interest on Refund Net of Interest Paid Under Section 220 Was Fully Disclosed During Original Assessment

19 Mar 2010

The petitioner, Arthur Anderson & Co., filed a writ petition under Article 226 of the Constitution challenging a notice dated 4 February 2009 issued b...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Change of Opinion. Reopening of Assessment Under Section 148 of Income Tax Act, 1961 Based on Mere Change of Opinion Without New Material is Invalid.

9 Jul 2012

The petitioner, M/s. Rabo India Finance Limited, a non-banking financial company, challenged a notice dated 28.3.2011 issued under Section 148 of the ...

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