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Bombay High Court Holds Reopening Beyond Four Years Requires Specific Disclosure Failure. General Statement of Non-Disclosure Not Sufficient Under Proviso to Section 147 Income Tax Act, 1961.

The petitioner, a real estate developer, challenged a notice dated 27/03/2019 issued under Section 148 of the Income Tax Act, 1961 for reopening the a...

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Bombay High Court Quashes Income Tax Reopening Notice Under Section 148 Due to Lack of Tangible Material and Failure to Disclose After Four Years. Reassessment Notice Based on Audit Objections and Mere Change of Opinion Barred by Proviso to Section 147 of Income Tax Act, 1961.

The writ petition arose from reassessment proceedings initiated against the petitioner company for Assessment Year 2012-2013. The petitioner filed its...