Search Results for "proviso to section 147"

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Search Results for "proviso to section 147"

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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 Quashes Reassessment Notice in Income Tax Case for Lack of Failure to Disclose Material Facts — Reassessment Initiated Beyond Four Years Invalid Without Proof of Non-Disclosure Under Section 147 Proviso of Income Tax Act, 1961

27 Jun 2023

The petitioner, Hindoostan Mills Limited, filed a writ petition under Article 226 of the Constitution challenging a notice dated 30th March 2021 issue...

High Court

Bombay High Court Quashes Reassessment Notices Under Section 148 of Income-Tax Act, 1961 for Lack of Reasonable Belief of Income Escaping Assessment. Notices Issued Beyond Four Years Without Fresh Material Held Invalid.

6 May 2022

The petitioner, Sea Sagar Construction Co., a partnership firm, filed three writ petitions challenging notices dated 19 January 2012 issued under Sect...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment after four years barred unless Revenue shows assessee failed to fully and truly disclose all material facts.

27 Apr 2022

The petitioner, Bhavani Gems Private Limited, challenged a notice dated 30.03.2021 issued under section 148 of the Income Tax Act, 1961 for reopening ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment After Four Years Invalid as Assessee Had Made Full Disclosure During Original Assessment Under Section 143(3).

24 Jan 2022

The petitioner, Glaxosmithkline Pharmaceuticals Ltd., challenged a notice dated 28 March 2019 issued under Section 148 of the Income Tax Act, 1961 for...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment initiated beyond four years without establishing that assessee failed to fully and truly disclose all material facts is invalid.

3 Jan 2022

The petitioner, Vodafone Idea Ltd., successor in interest of M/s Idea Cellular Ltd., filed a writ petition challenging a notice dated 2nd August 2019 ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose — Reassessment Beyond Four Years Invalid Without Allegation of Non-Disclosure

24 Jan 2012

The petitioner, DIL Ltd., challenged a notice dated 8 March 2011 issued under Section 148 of the Income Tax Act, 1961, seeking to reopen the assessmen...

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