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Search Results for "reopening after four years"

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High Court

Bombay High Court Allows Petitioner in Income Tax Reassessment Case Due to Lack of Fresh Material and No Failure to Disclose. Reopening Beyond Four Years Invalid as Revenue Failed to Allege Non-Disclosure Under Section 147 of Income Tax Act, 1961.

2 Feb 2024

The petitioner, Sun Tan Trading Co. Ltd., is engaged in the business of import and distribution of alcoholic beverages in India. It had entered into a...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 — Notice Issued Beyond Limitation Period. Reopening Based on Non-Escapement of Income as Assessee Had Already Disclosed Full Details During Original Assessment.

23 Jan 2024

The petitioner, Bajaj Energy Limited, a company engaged in energy business, filed its return of income for Assessment Year 2014-15 on 30th November 20...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Fresh Material. Reopening of Assessment Under Section 147 of Income Tax Act, 1961 Invalid When Based on Same Material Already Considered in Original Assessment.

25 Aug 2023

The petitioner, Siemens Financial Services Pvt Ltd, a Non-Banking Finance Company registered with RBI, filed its return of income for Assessment Year ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reopening Based on Same Material Considered in Original Scrutiny Assessment is Invalid.

9 Jan 2023

The petitioner, Clear Media (India) Private Limited, a company engaged in FM Radio Broadcasting, filed its return of income for the assessment year 20...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Change of Opinion. Notice under Section 148 of Income Tax Act, 1961 for reassessment of derivative transaction loss set aside as Assessing Officer had already examined the issue during original assessment.

22 Apr 2022

The petitioner, Shrikant Phulchand Bhakkad (HUF), through its Karta, filed a writ petition under Article 226 of the Constitution of India challenging ...

High Court

Bombay High Court Quashes Reopening Notices Under Section 148 of Income Tax Act for Lack of Fresh Material. Reassessment Based on Change of Opinion Without New Tangible Material is Invalid.

27 Mar 2015

The petitioner, M/s. Alliance Space Pvt. Ltd., a company engaged in property development, challenged two notices dated 24th March 2015 and 29th March ...

High Court

Bombay High Court Quashes Reassessment Notice Against Russian Company in Nuclear Power Project Tax Dispute — Lack of Fresh Material and Mechanical Approval of Sanction Invalidates Reopening Under Section 147 of Income Tax Act, 1961. Offshore Supply Contracts Not Taxable in India as Per Original Assessment; Reopening Based on Change of Opinion Not Permissible.

1 Aug 2012

The petitioner, Atomstroyexport, a Russian joint stock company, challenged the jurisdiction of the Deputy Director of Income Tax (International Taxati...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 — Depreciation on Goodwill Not a Valid Reason for Reassessment. The court held that reopening based on change of opinion is impermissible and that depreciation on goodwill is allowable under Section 32(1)(ii) of the Income Tax Act, 1961.

25 Jun 2012

The petitioner, Bedmutha Industries Ltd., challenged a notice dated 29 November 2010 issued under Section 148 of the Income Tax Act, 1961, seeking to ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 Income Tax Act for Mere Change of Opinion. Assessment Completed Under Section 143(3) Cannot Be Reopened Without Fresh Tangible Material.

19 Dec 2011

The petitioner, Sanand Properties Pvt. Ltd., filed a return for Assessment Year 2008-09 declaring income of Rs.20.33 lakhs, later revised to Rs.19.14 ...

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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