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Search Results for "reopening after four years"

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High Court

Bombay High Court Quashes Reassessment Order for Lack of Proper Opportunity of Hearing and Non-Communication of Section 151 Approval in Income Tax Reopening Proceedings. The court held that the Assessing Officer failed to grant a personal hearing as directed by the earlier order of the High Court and did not communicate the approval under Section 151 of the Income Tax Act, 1961, rendering the reassessment invalid.

20 Dec 2024

The petitioner, Wavy Construction LLP, challenged an order dated 14 October 2021 rejecting its objections against reopening of assessment under Sectio...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case — No Failure to Disclose Material Facts. Reopening Beyond Four Years Invalid Under Section 147/148 of Income Tax Act, 1961 as Original Assessment Under Section 143(3) Was Full and True Disclosure.

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 Under Section 148 of Income-tax Act, 1961 for Lack of Fresh Material. Assessment Reopened Beyond Four Years Based on Reappraisal of Same Facts Without Allegation of Failure to Disclose Material Facts Held Invalid.

25 Sep 2023

The petitioner, CitiusTech Healthcare Technology Pvt. Ltd., filed a writ petition challenging a notice dated 27 March 2021 issued under Section 148 of...

High Court

Bombay High Court Quashes Reassessment Notice for TCS in Income Tax Case — Lack of Fresh Material and Change of Opinion. Reopening under Section 147 of Income Tax Act, 1961 invalid as reasons recorded were based on same material considered during original assessment, constituting mere change of opinion.

27 Jun 2023

The petitioner, Tata Consultancy Services Ltd., challenged a notice dated 31st March 2021 issued under Section 148 of the Income Tax Act, 1961 seeking...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reassessment Case — Reopening Based on Change of Opinion Invalid. ITAT Correctly Held That Reassessment Under Section 147 Was Not Justified as There Was No Failure to Disclose Material Facts.

31 Jul 2019

The case involves a tax appeal by the Commissioner of Income Tax against the order of the Income Tax Appellate Tribunal (ITAT) which upheld the cancel...

High Court

Bombay High Court Allows Writ Petition Quashing Reopening Notice Under Section 148 Income Tax Act for Assessment Year 2000-01 — Reassessment Based on Change of Opinion Invalid. The court held that the Assessing Officer cannot reopen an assessment beyond four years on the same material already considered during the original assessment under section 143(3) of the Income Tax Act, 1961.

5 Jan 2015

The petitioner, United Shippers Limited, challenged a notice dated 15 March 2007 issued under section 148 of the Income Tax Act, 1961 by the Assistant...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Fresh Material. Reopening of Assessment Under Section 147/148 of Income Tax Act, 1961 Based on Mere Change of Opinion Without New Tangible Material is Invalid.

14 Feb 2014

The petitioner, M/s. Crown Consultants Pvt. Ltd., a share and stock broker, filed its return of income for assessment year 2007-08 on 30 October 2007 ...

High Court

Bombay High Court Allows Writ Petition Quashing Reopening of Assessment Under Section 148 of Income Tax Act, 1961 for Assessment Year 2004-05. Mere Change of Opinion Cannot Justify Reopening When All Material Facts Were Disclosed During Original Assessment Under Section 143(3).

31 Jan 2012

The petitioner, Shri Mahila Griha Udyog Lijjat Papad, a society registered under the Societies Registration Act, 1960 and the Bombay Public Trust Act,...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 for Lack of Fresh Material. Reassessment Based on Mere Change of Opinion on Exemption Under Section 10(38) of Income Tax Act, 1961 is Invalid.

1 Dec 2011

The Petitioner, General Insurance Corporation of India, a public sector general insurance company, filed a return of income for Assessment Year 2006-0...

High Court

Bombay High Court Allows Writ Petition Challenging Reassessment Notices for Non-Disclosure of Reasons. Failure to Supply Recorded Reasons Under Section 147 of Income Tax Act, 1961 Violates Natural Justice and Renders Reopening Invalid.

16 Aug 2005

The petitioner, Ajay Oxycholoride Floorings, a partnership firm, challenged two notices dated 20th February 1990 and 3rd June 1991 issued by the Assis...

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