Search Results for "Section 147 Income Tax Act"

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Search Results for "Section 147 Income Tax Act"

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High Court

Bombay High Court Quashes Reassessment Notice for Co-operative Bank Due to Lack of Failure to Disclose Material Facts — Reassessment Initiated Beyond Four Years Invalid Under Section 147 Proviso. The Court held that the Revenue's reasons for reopening were based on a mere change of opinion on the same disclosed facts, failing to satisfy the jurisdictional precondition of failure to disclose fully and truly all material facts.

26 Aug 2024

The Petitioner, The Saraswat Co-operative Bank Ltd., filed a Writ Petition challenging a reassessment notice dated 30 March 2021 issued under Section ...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Change of Opinion — Reopening Under Section 147 Invalid as Issue Already Decided by CIT(A) in Favour of Assessee. The court held that the reassessment notice under Section 148 was based on the same issue already decided by the appellate authority, constituting a change of opinion and barred by the proviso to Section 147 of the Income Tax Act, 1961.

26 Apr 2024

The petitioner, M/s. Poonam Builders, an Association of Persons (AOP) engaged in construction business, completed a residential project named 'Harsh V...

High Court

Bombay High Court Dismisses Petitioner's Challenge to Reopening of Assessment Under Section 147 of Income Tax Act, 1961 — Reopening Based on Tangible Material from Investigation Wing and Not a Mere Change of Opinion. Failure to Disclose Primary Facts During Original Assessment Justifies Reopening Within Four Years.

8 Sep 2023

The petitioner, Vaman Prestressing Co. Pvt. Ltd., filed two writ petitions challenging the reopening of its assessment for the Assessment Year 2006-07...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Full and True Disclosure — Petitioner Had Disclosed All Material Facts in Return of Income. The court held that the reopening was based on a change of opinion and was invalid as the Assessing Officer did not form a reasonable belief of escapement of income.

7 Aug 2023

The petitioner, Astec LifeSciences Ltd., is engaged in the business of manufacturing and trading of agrochemicals and pharmaceutical intermediates. Wi...

Supreme Court

Supreme Court Dismisses Revenue's Appeal Against Quashing of Reassessment Notice Under Income Tax Act Due to Lack of Tangible Material and Improper Reliance on Income Declaration Scheme. Reassessment Initiated Based on Accommodation Entries and Declaration Under Section 183 of Finance Act, 2016 Held Invalid as AO Failed to Establish 'Reasons to Believe' Income Escaped Assessment for AY 2010-11.

28 Mar 2022

The dispute arose from a reassessment notice issued by the Commissioner of Income Tax under Sections 147/148 of the Income Tax Act, 1961, for the asse...

Supreme Court

Supreme Court Allows Appeal in GST Provisional Attachment Case, Reversing High Court's Dismissal on Maintainability Grounds. The High Court Erred in Dismissing Writ Petition Solely Due to Alternative Remedy Under Section 107 of the Himachal Pradesh Goods and Services Tax Act, 2017, Without Examining Merits of Provisional Attachment Orders Under Section 83.

20 Apr 2021

The appeal arose from a judgment dated 1 January 2021 by the High Court of Himachal Pradesh, which dismissed a writ petition under Article 226 of the ...

High Court

Bombay High Court Upholds Penalty for Concealment of Income in Income Tax Reference. Minimum penalty under Section 271(1)(c) of the Income Tax Act, 1961 sustained for suppression of net profit of Rs.9,11,521/-.

22 Aug 2017

The case pertains to an Income Tax Reference under Section 256(1) of the Income Tax Act, 1961, arising from proceedings for the Assessment Year 1987-8...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income Tax Act, 1961 for Non-Resident Company — Lack of Reasonable Belief of Income Escaping Assessment. Reassessment Based on Mere Change of Opinion is Impermissible; Notice and Order Rejecting Objections Set Aside.

13 Mar 2012

The petitioner, Indivest Pte Ltd, a company incorporated in Singapore and wholly owned by the Government of Singapore, filed a writ petition challengi...

High Court

Bombay High Court Allows Writ Petition Challenging Settlement Commission's Power to Levy Interest Under Section 234B When No Interest Was Charged in Original Assessment. Interest under Section 234B(4) can only be increased or reduced if it was initially chargeable under the original assessment order.

2 Jul 2010

The petitioner, Akbar Travels of India Pvt. Ltd., an IATA approved travel agent and money changer, filed returns for Assessment Years 2002-03 to 2006-...

High Court

Bombay High Court at Goa Dismisses Tax Appeals in Reassessment Cases Under Section 147 of Income Tax Act, 1961. No Substantial Question of Law Found as Tribunal's Findings Were Based on Appreciation of Evidence.

30 Nov -0001

The judgment pertains to multiple tax appeals filed by individual assessees against the Commissioner of Income Tax, Goa. The appellants, including Sha...

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