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Search Results for "reopening after four years"

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High Court

High Court Quashes Income Tax Reopening Notices in Search-Based Assessment Cases Due to Mandatory Application of Section 153C. Assessing Officer Cannot Invoke General Reassessment Provisions Under Sections 147/148 When Material Originates from Search Under Section 132/132A, as Special Provisions Under Section 153C Override and Require Exclusive Procedural Compliance.

7 Jan 2026

The judgment concerned a group of petitions challenging notices issued under Section 148 of the Income-tax Act, 1961, reopening assessments under Sect...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Prior Recording of Reasons. Reopening under Section 148 of Income Tax Act, 1961 Held Invalid as Reasons Not Recorded Before Issuance of Notice.

20 Feb 2025

The petitioner, M/s. Indusind Media & Communications Ltd., filed its return of income for assessment year 2007-08, which was revised and subsequently ...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Beyond Four Years Under Section 147 of Income Tax Act, 1961 — No Failure to Disclose Material Facts. Reopening Based on Change of Opinion Not Permissible; Notice Under Section 148 Quashed.

8 Nov 2023

The petitioner, Hasmukh Estates Pvt. Ltd., a company registered under the Companies Act, 1956/2013, filed a writ petition under Article 226 of the Con...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income-tax Act for Lack of Fresh Material — Reopening Based on Mere Change of Opinion Not Permissible. The Court held that where the Assessing Officer had already examined the issue of sundry creditors during original scrutiny assessment under Section 143(3), reopening on the same ground without fresh tangible information is invalid.

15 Feb 2023

The Petitioner, Punia Capital Pvt. Ltd., challenged the validity of a notice under Section 148 of the Income-tax Act, 1961 and the consequent reopenin...

High Court

Bombay High Court Allows Petitioner in Income Tax Reassessment Case — Mushroom Farming Income Held Agricultural. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Quashed as Based on Change of Opinion.

11 Apr 2018

The petitioner, Zuari Foods and Farms Pvt. Ltd., a private limited company engaged in mushroom farming, filed its income tax return for assessment yea...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Reasonable Belief and Change of Opinion. Reassessment Beyond Four Years Invalid Without Allegation of Failure to Disclose Material Facts.

7 Apr 2015

The petitioner, Nivi Trading Limited, a private limited company, filed its return of income for Assessment Year 2010-11 on 15th September 2010 declari...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction — Dell India Pvt. Ltd. v. Joint Commissioner of Income Tax. Notice under Section 148 of Income Tax Act, 1961 issued without proper sanction and by officer lacking territorial jurisdiction over assessee.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is a company engaged in the manufacture and sale of computer hardware and related products. For the Assessment Y...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reassessment Based on Mere Change of Opinion Invalid. The court held that the Assessing Officer's acceptance of the return under Section 143(1) after considering the Section 10A deduction claim precludes reopening without fresh tangible material.

16 Sep 2013

The petitioner, Sitara Diamond Pvt. Ltd., challenged a notice dated 3 May 2012 issued under Section 148 of the Income Tax Act, 1961, seeking to reasse...

High Court

Bombay High Court Quashes Reopening of Assessment in Income Tax Case — No Failure to Disclose Material Facts. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Held Invalid as Original Assessment Was Based on Full Disclosure and Scrutiny.

17 Feb 2010

The petitioner, Multiscreen Media Private Limited, is engaged in the business of providing audiovisual television content, films, events, and related ...

High Court

Bombay High Court Quashes Reopening Notices Under Section 148 of Income Tax Act for Lack of Reasonable Belief of Income Escaping Assessment. Reassessment Initiated Beyond Four Years Without Fresh Material or Failure to Disclose by Assessee is Invalid.

28 Oct 2005

The judgment concerns two writ petitions filed by M/s German Remedies Ltd., a public limited company engaged in manufacturing pharmaceutical products,...

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