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Search Results for "reopening notice"

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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 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 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 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 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 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 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 in Income Tax Case Due to Lack of Fresh Material Beyond Four Years. Unabsorbed Depreciation Set-Off and Book Profit Adjustments Under Section 115JB of Income Tax Act, 1961 Not Justified for Reopening.

15 Feb 2012

The petitioner, Voltas Limited, filed a writ petition challenging a notice dated 30 March 2011 issued under Section 148 of the Income Tax Act, 1961, s...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 147 of Income Tax Act, 1961 — Survey Material Not Sufficient for Reasonable Belief of Escapement of Income. The court held that a survey under Section 133A does not provide 'information' for reopening, and the reasons recorded must show a live link between the material and the belief of escapement.

17 Oct 2011

The petitioner, Yash Raj Films Private Limited, challenged the reopening of its income tax assessments for Assessment Years 2005-06 and 2006-07 under ...

High Court

Bombay High Court Quashes Reassessment Notices for HUF Assessee in Income Tax Case — Lack of Reasonable Belief of Income Escaping Assessment. Notices under Section 148 of Income Tax Act, 1961 set aside as reasons for reopening were based on mere change of opinion and not on fresh tangible material.

5 Sep 2006

The petitioner, a Hindu Undivided Family (HUF) carrying on cotton ginning and pressing business, challenged four notices dated 30 March 2004 issued un...

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