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Search Results for "reopen assessment"

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High Court

Gujarat High Court Quashes Reassessment Notice in Income Tax Case Due to Non-Application of Mind by AO. Section 148 Notice for AY 2014-15 Set Aside as Reasons Recorded Were Mechanical and Lacked Independent Satisfaction.

20 Mar 2026

The petitioner, Sanvira Holdings, a partnership firm part of the PSY Group engaged in real estate business, filed its return of income for Assessment ...

High Court

Gujarat High Court Quashes Reassessment Notice for AY 2014-15 Due to Limitation Under Section 149(1)(b) of Income Tax Act, 1961. Notice issued beyond six-year period from end of assessment year held invalid as escaped income did not involve assets of value exceeding Rs. 50 lakhs.

20 Mar 2026

The petitioner, a major partner of PSY Group engaged in real estate business, challenged a notice dated 27.03.2025 issued under Section 148 of the Inc...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Non-Application of Mind. Notice Issued Based on Search Materials Without Independent Satisfaction or Opportunity of Hearing Held Invalid.

9 Mar 2026

The petitioner, Dilipbhai Prabhudas Patel, an individual and part of the PSY Group engaged in real estate business, filed his return of income for Ass...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Search Action Under Section 132 Cannot Be Basis for Reopening Beyond Four Years Without New Tangible Evidence.

23 Feb 2026

The petitioner, Mahesh Dharamshi Prajapati, an individual and major partner of PSY Group engaged in real estate business, filed his return of income f...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material. Reopening Under Section 148 of Income Tax Act, 1961 Based on Mere Change of Opinion on Provision for Unascertained Liabilities is Invalid.

26 Feb 2024

The petitioner, Bajaj Auto Limited, filed its return of income for Assessment Year 2016-17 on 29 November 2016, declaring total income of Rs. 4,860,25...

High Court

Bombay High Court Quashes Reopening Notice in HDFC Bank Bad Debts Case — No Failure to Disclose Material Facts. Section 148 notice under Income Tax Act, 1961 set aside as reassessment based on change of opinion and lack of tangible material.

1 Mar 2022

The petitioner, HDFC Bank Ltd., a scheduled bank registered with RBI, filed its return of income for assessment year 2006-07 and claimed deductions un...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reopening Based on Mere Change of Opinion on Disallowance Under Section 40(a)(ia) is Invalid.

4 Dec 2012

The petitioner, M/s. NDT Systems, a partnership firm engaged in non-destructive testing business, filed its return of income for assessment year 2007-...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Full and True Disclosure — Investment in Bonds Prior to Sale of Property Does Not Disentitle Deduction Under Section 54EC. The Court held that the assessee had disclosed all material facts and the reopening was based on a change of opinion, thus invalid.

27 Jun 2012

The petitioner, Mrs. Parveen P. Bharucha, filed a writ petition under Article 226 of the Constitution of India challenging a notice dated 31.03.2011 i...

High Court

Bombay High Court Quashes Reassessment Notice for Lack of Fresh Material — Section 10A Deduction Cannot Be Reopened Based on Subsequent Year's Findings Without Independent Reason to Believe. The Court held that reopening of assessment under Section 148 requires independent material and cannot be based on a change of opinion or findings from a later assessment year.

9 Feb 2012

The petitioner, Siemens Information Systems Limited, filed its return of income for Assessment Year 2004-05 declaring nil income after claiming a dedu...

High Court

Bombay High Court Quashes Reopening of Assessments for Life Insurance Company Due to Change of Opinion and Lack of Full Disclosure. Reassessment notices under Section 147 of Income Tax Act, 1961 for AY 2002-03, 2003-04, and 2004-05 held invalid as the Assessing Officer had already examined the method of computation under Section 44 of Insurance Act, 1938 during original assessment.

8 Mar 2010

The petitioner, ICICI Prudential Life Insurance Company Limited, is a life insurance company registered under the Insurance Act, 1938. It filed its re...

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