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Search Results for "reopening notice"

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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 Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material. Reopening Under Section 148 of Income Tax Act, 1961 Based on Mere Change of Opinion on Provision for Unascertained Liabilities is Invalid.

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 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 Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Mere Change of Opinion Without New Tangible Material is Invalid.

13 Mar 2018

The petitioner, Zuari Foods and Farms Pvt. Ltd., filed its return of income for Assessment Year 2011-12 declaring nil income after claiming exemption ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reopening Based on Mere Change of Opinion on Disallowance Under Section 40(a)(ia) is Invalid.

4 Dec 2012

The petitioner, M/s. NDT Systems, a partnership firm engaged in non-destructive testing business, filed its return of income for assessment year 2007-...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material Beyond Four Years. Reopening Based on Change of Opinion Regarding Melting Loss Percentage Not Valid as Original Assessment Under Section 143(3) Had Examined the Issue.

30 Mar 2012

The petitioner, Sound Casting Pvt. Ltd., challenged a notice under Section 148 of the Income Tax Act, 1961 seeking to reopen its assessment for Assess...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reopening Case — Reopening Invalid Due to Change of Opinion. Tribunal's finding that reassessment notice was based on mere change of opinion upheld under Section 147 of Income Tax Act, 1961.

5 Sep 2011

The case pertains to an appeal by the Revenue against the order of the Income Tax Appellate Tribunal (ITAT) which held that the reopening of assessmen...

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 ...

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