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Search Results for "Section 148A"

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High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Assessment Year 2014-2015 — Notice Issued Beyond Surviving Time Under TOLA Held Invalid. The court applied the principle of 'surviving time' from Union of India v. Rajeev Bansal to determine that the notice dated 30.07.2022 was time-barred as the period between the original TOLA notice and 30.06.2021 was less than the time required for compliance.

3 Mar 2026

The petitioner, Ashokbhai Nanubhai Patel, filed a Special Civil Application under Article 226 of the Constitution of India challenging a notice dated ...

High Court

High Court of Gujarat Quashes Reassessment Notice Issued Under Section 148A(d) and Section 148 of Income Tax Act, 1961 for Assessment Year 2018-19. Reassessment on ground that capital gains should be treated as business income due to change in directors was impermissible as same issue was already examined in original scrutiny assessment under Section 143(3), constituting a mere change of opinion.

10 Mar 2026

The petitioner, an individual assessee, filed a return of income for Assessment Year 2018-19 on 27.07.2018 declaring total income of Rs. 27,26,64,000/...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Proper Sanction Under Section 151. Sanctioning Authority Must Apply Independent Mind and Not Merely Rely on Proposal of Assessing Officer.

24 Feb 2026

The petitioner, Gulbrandsen Private Limited, filed a writ petition before the Gujarat High Court challenging a notice dated 16.06.2025 issued under Se...

High Court

Bombay High Court Quashes Reassessment Notice in International Tax Case for Violation of Faceless Assessment Scheme. Jurisdictional Assessing Officer Lacks Authority to Issue Notice Under Section 148 Outside Faceless Mechanism Under Section 151A of Income Tax Act, 1961.

28 Aug 2024

The petitioner, Abhin Anilkumar Shah, challenged a notice dated 31 March 2021 issued under Section 148A(b), an order dated 19 April 2024 under Section...

High Court

Madras High Court Quashes Reassessment Notice Under Section 148 Income Tax Act as Time-Barred; Notice Dispatched on 1st April 2021 Beyond Limitation. Reopening Based on Accommodation Entry Information Without Independent Material Held Invalid for AY 2013-14.

20 Feb 2025

The petitioner, a proprietor of a petrol bunk, challenged a reassessment notice under Section 148 of the Income Tax Act, 1961 for Assessment Year 2013...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148A(d) of Income Tax Act for Mechanical Disposal Without Application of Mind. Failure to Consider Assessee's Detailed Response Violates Principles of Natural Justice, Rendering Subsequent Section 148 Notice Invalid.

19 Feb 2026

The petitioner, Laxmi Infra Developers Limited, challenged a notice under Section 148A(b) of the Income Tax Act, 1961, dated 24.03.2022, proposing rea...

High Court

Gujarat High Court Quashes Reassessment Notice in Income Tax Proceeding for Being Time-Barred Based on Surviving Time Principle. Reassessment notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2016-17 was held invalid as it was issued beyond the surviving time limit as per the Supreme Court's decision in Union of India vs. Ashish Agarwal and Rajeev Bansal.

12 Mar 2026

Background: The matter arose from a reassessment proceeding initiated by the Assistant Commissioner of Income Tax, Circle Gandhinagar against M/s Amma...

High Court

High Court of Karnataka Quashes Reassessment Notice Under Section 148A(b) of Income Tax Act, 1961 for Lack of Proper Application of Mind. Notice and Order Set Aside as Show Cause Notice Did Not Disclose Reasons for Reopening Assessment Beyond Four Years.

27 Sep 2024

The petitioner, Anand Kumar Somasheshekarayya Lonarmath, filed a writ petition under Articles 226 and 227 of the Constitution of India before the High...

High Court

Bombay High Court Quashes Reassessment Notice Issued by Jurisdictional Assessing Officer Instead of Faceless Assessing Officer Under Section 148 of Income Tax Act, 1961 — Violation of Section 151A and Faceless Scheme Renders Proceedings Invalid.

5 Aug 2024

The petitioner, Kairos Properties Private Limited, filed a writ petition under Article 226 of the Constitution of India challenging a notice dated 25 ...

High Court

Gujarat High Court Quashes Reassessment Notice in Income Tax Act Case as Time-Barred Under Surviving Time Principle. Notice Under Section 148 for AY 2017-2018 Issued Beyond Computed Limitation of 18.07.2022 Rendered Invalid.

3 Mar 2026

The dispute originated from a reassessment notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2017-2018. The respondent A...

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