Search Results for "reopening after four years"

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Search Results for "reopening after four years"

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High Court

Bombay High Court Quashes Reassessment Notice and Order in Income Tax Case Due to Lack of Fresh Material and Change of Opinion. Guarantee Fee Reversal Issue Already Examined in Original Assessment and Pending Before Tribunal, Reassessment Barred by Third Proviso to Section 147 of Income-tax Act, 1961.

7 Mar 2025

The petitioner, Tata Communications Limited, filed its return of income for Assessment Year 2014-15 on 24 November 2014, which was revised twice in Ma...

Supreme Court

Supreme Court Upholds Revenue in Income Tax Reassessment Case on Limitation and Computation Grounds. Reassessment under Sections 147 and 148 of Income Tax Act, 1961 Held Valid as Assessee Failed to Disclose Material Facts, and Notice Served on Partnership Firm Was Proper Despite Section 282(2) Argument.

23 Jan 2024

The dispute arose from reassessment proceedings under the Income Tax Act, 1961, involving a partnership firm engaged in publishing newspapers and peri...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Same Material as Original Assessment Without New Tangible Information is Invalid.

6 Oct 2023

The petitioner, an individual assessee, filed his return of income for Assessment Year 2006-07 on 26 October 2007 declaring total income of Rs.2,84,19...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Reasonable Belief of Income Escaping Assessment. Share Premium Reassessment Based on Intrinsic Valuation Without New Material Held Invalid Under Section 147 of the Income Tax Act, 1961.

27 Jun 2023

The petitioner, SLS Energy Pvt. Ltd., challenged a notice dated 23 March 2015 issued under Section 148 of the Income Tax Act, 1961, for the assessment...

High Court

Bombay High Court Quashes Reassessment Notice Against Charitable Trust for Lack of Fresh Material. Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts Under Section 147 of Income Tax Act, 1961.

8 Mar 2023

The petitioner, Framji Dinshaw Petit Parsee Sanatorium, is a public charitable trust registered under section 12A of the Income Tax Act, 1961. For the...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reassessment Based on Same Facts as Original Assessment is Invalid. The court held that a notice under section 148 cannot be issued on the same material already considered during scrutiny assessment under section 143(3), as it amounts to a change of opinion.

20 Feb 2023

The petitioner, Survival Technologies Pvt. Ltd., filed a writ petition challenging a notice dated 30 March 2021 issued under section 148 of the Income...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Assessment Reopened Beyond Four Years Based on Mere Change of Opinion Without New Tangible Material, Violating Section 147 Proviso.

17 Jan 2022

The petitioner, Macrotech Developers Limited (successor to Palava Dwellers Pvt. Ltd.), challenged a notice dated 27 March 2019 issued under Section 14...

High Court

Bombay High Court Allows Petition Challenging Reassessment Notice Under Section 148 of Income Tax Act — Reassessment Based on Mere Change of Opinion Invalid as Full Disclosure Was Made During Original Assessment.

25 Mar 2015

The petitioner, Plus Paper Food Pac Ltd., filed a writ petition challenging a notice dated 18.11.2013 issued under Section 148 of the Income Tax Act, ...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income-tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Change of Opinion on Commission Payment to Directors Held Invalid as All Issues Were Examined During Original Assessment.

7 May 2013

The Petitioner, M/s. Dalal & Broacha Stock Broking Pvt. Ltd., a stock broking company, filed its return of income for Assessment Year 2008-09 declarin...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material Beyond Four Years. Reassessment Cannot Be Based Solely on Subsequent Year's Assessment Order Without Allegation of Failure to Disclose Material Facts.

24 Jan 2012

The Petitioner, Sitara Diamond Pvt. Ltd., filed a writ petition under Article 226 of the Constitution challenging a notice dated 20 June 2011 issued u...

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