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Search Results for "queries during assessment"

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High Court

Karnataka High Court Adjudicates upon Writ Petitions Challenging Re-Assessment Proceedings for Assessment Years 2005-06 to 2007-08. Court Analyzes Whether Notices are Barred by Limitation and Whether Assessee Failed to Disclose Material Facts.

19 Dec 2023

The petitioner, EIT Services India Pvt. Ltd. (formerly Hewlett Packard Globalsoft Private Limited), a company engaged in export of software services a...

High Court

Bombay High Court Quashes Reassessment Notices Under Section 148 of Income Tax Act for Lack of Fresh Material. Reassessment Based on Mere Change of Opinion Without New Tangible Material is Invalid.

8 May 2014

The petitioner, Debashu Services Private Limited, a private limited company registered under the Companies Act, 1956, is a regular assessee under the ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Reasonable Belief. Reassessment Based on Borrowed Satisfaction from Investigation Wing Without Independent Application of Mind by Assessing Officer is Invalid.

18 Jan 2016

The Petitioner, Nirmal Bang Securities Pvt. Ltd., challenged a notice dated 30th March 2007 issued under Section 148 of the Income Tax Act, 1961 for r...

High Court

High Court of Gujarat Quashes Reassessment Notice Issued Under Section 148A(d) and Section 148 of Income Tax Act, 1961 for Assessment Year 2018-19. Reassessment on ground that capital gains should be treated as business income due to change in directors was impermissible as same issue was already examined in original scrutiny assessment under Section 143(3), constituting a mere change of opinion.

10 Mar 2026

The petitioner, an individual assessee, filed a return of income for Assessment Year 2018-19 on 27.07.2018 declaring total income of Rs. 27,26,64,000/...

High Court

Bombay High Court Quashes Reassessment Notice Against Russian Company in Nuclear Power Project Tax Dispute — Lack of Fresh Material and Mechanical Approval of Sanction Invalidates Reopening Under Section 147 of Income Tax Act, 1961. Offshore Supply Contracts Not Taxable in India as Per Original Assessment; Reopening Based on Change of Opinion Not Permissible.

1 Aug 2012

The petitioner, Atomstroyexport, a Russian joint stock company, challenged the jurisdiction of the Deputy Director of Income Tax (International Taxati...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case — No Failure to Disclose Material Facts. Reopening Beyond Four Years Invalid Under Section 147/148 of Income Tax Act, 1961 as Original Assessment Under Section 143(3) Was Full and True Disclosure.

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

High Court of Bombay at Goa Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts. The court held that the Assessing Officer cannot reopen assessment on the same material already examined during scrutiny, as it amounts to a change of opinion.

6 Mar 2018

The petitioner, Dempo Brothers Private Limited, a company incorporated under the Companies Act, filed its return of income for Assessment Year 2010-11...

High Court

Karnataka High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act Due to Lack of Tangible Material and Mere Change of Opinion. Reopening of Assessment After Full Disclosure and Acceptance of Logo Fee as Revenue Expenditure in Previous Years Held Impermissible.

10 Aug 2018

The writ petition was filed by the assessee, a limited company manufacturing kitchen appliances, challenging a notice dated 11.02.2014 issued under Se...

High Court

Bombay High Court Hears Writ Petition Challenging Validity of Reopening Notice Under Section 148 of Income Tax Act for Assessment Year 2015-16. The Reopening Based on Alleged Escaped Income from Capital Reduction Transaction Is Contested on Grounds of Full Disclosure During Original Assessment.

8 Mar 2023

The petitioner, an investment holding company incorporated in Singapore and under creditors' voluntary liquidation, held shares in Lehman Brothers Cap...

High Court

Bombay High Court Quashes Reopening of Assessments for Life Insurance Company Due to Change of Opinion and Lack of Full Disclosure. Reassessment notices under Section 147 of Income Tax Act, 1961 for AY 2002-03, 2003-04, and 2004-05 held invalid as the Assessing Officer had already examined the method of computation under Section 44 of Insurance Act, 1938 during original assessment.

8 Mar 2010

The petitioner, ICICI Prudential Life Insurance Company Limited, is a life insurance company registered under the Insurance Act, 1938. It filed its re...

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