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Search Results for "reopening of assessment"

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High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Mere Change of Opinion Not Sufficient to Reopen Assessment After Four Years. The court held that where the original assessment was completed under Section 143(3) after due inquiry, reopening beyond four years requires failure to disclose material facts, which was not established.

18 Jul 2011

The petitioner, Nihilent Technologies Private Limited, a private limited company engaged in software development, challenged a notice dated 29 March 2...

High Court

High Court of Bombay at Goa Quashes Reopening Notice Under Section 147 of Income Tax Act, 1961 for Lack of Full and True Disclosure. Assessee's Claim for Deduction Under Section 80-IA Was Considered During Original Assessment, Hence No Failure to Disclose Material Facts.

9 Jun 2011

The petitioner, Titanor Components Limited, an assessee under the Income Tax Act, 1961, challenged a notice issued under Section 147 of the Act for re...

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

Gujarat High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Non-Compliance with Section 148A(b) Procedure. Notice Issued After 01.04.2021 Without Following Mandatory Procedure Under Section 148A(b) of Income Tax Act, 1961 is Invalid Despite TOLA Extension.

3 Mar 2026

The petitioner, Jayeshkumar Narsidas Madlani, filed a Special Civil Application under Article 226 of the Constitution challenging a notice issued unde...

High Court

Gujarat High Court Quashes Reassessment Notice Against Elderly Housewife in Income Tax Case — Lack of Jurisdictional Satisfaction and Non-Application of Mind. Reopening of Assessment Under Section 147/148 of Income Tax Act, 1961 Set Aside as Notice Was Issued Without Proper Inquiry and Without Considering Petitioner's Status as Non-Filer.

30 Mar 2026

The petitioner, Muktaben Jadavjibhai Patel, an elderly housewife with no regular source of income, had never obtained a PAN or filed any return of inc...

High Court

Gujarat High Court Allows Petition Challenging Reopening Notice Under Section 148 for AY 2012-13 as Time-Barred. Notice Issued Beyond Six-Year Limit Under Section 149 After Search Under Section 132 on 08.09.2021.

23 Feb 2026

The petitioner, Manojbhai Bhupatbhai Vadodaria, filed a writ petition challenging a notice under Section 148 of the Income Tax Act, 1961 for Assessmen...

High Court

Gujarat High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Assessment Year 2015-16 Due to Lack of Live Link and Absence of Allegation of Failure to Disclose Material Facts. Notice Issued Beyond Four Years Without Proper Satisfaction That Income Escaped Assessment Due to Assessee's Failure to Disclose Material Facts.

26 Feb 2026

The petitioner, Jaini Tradelink Pvt. Ltd., a company engaged in wholesale and retail trade and acting as a commission agent, filed its return of incom...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Reassessment based on change of opinion without new tangible material is invalid.

21 Nov 2017

The petitioner, an individual assessee, filed his income tax return for Assessment Year 2010-11 on 30 March 2011 declaring income of ₹1.70 Crore and...

High Court

Bombay High Court Upholds Reopening of Assessment Under Section 147(a) for Income Tax on Minimum Guarantee Receipts from Film Sale. Assessee's Failure to Disclose Full Consideration for Sale of Movie 'Charas' Justifies Reassessment Despite Partial Acceptance of Addition.

17 Nov 2017

The case involves an income tax reference at the instance of the assessee, who sold a movie titled 'Charas' to M/s. Prakash Pictures on a minimum guar...

High Court

Bombay High Court Quashes Reopening Notice in Income Tax Case Due to Lack of Fresh Material — Mere Change of Opinion Not Sufficient for Reassessment Under Section 147 of Income Tax Act, 1961. The court held that the assessing officer cannot reopen an assessment under Section 147 based on the same return already processed under Section 143(1) without any new tangible material, as it would amount to a mere change of opinion.

14 Dec 2018

The petitioner, an individual, filed his return of income for Assessment Year 2013-14 declaring total income of Rs. 65,51,360/-. The return was accept...

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