S.147: Reassessment-Faceless assessment-Objections to reopening-Mechanical disposal of objections-Matter remanded.[S. 144B, 148, Art. 226]
EPL Ltd. v. DCIT [2025] 174 taxmann.com 159 (Bom) (HC)S.147: Reassessment-Faceless assessment-Objections to reopening-Mechanical disposal of objections-Matter remanded.[S. 144B, 148, Art. 226]
EPL Ltd. v. DCIT [2025] 174 taxmann.com 159 (Bom) (HC)S. 147: Reassessment-Claim was pending in appeal-Claim for deduction under section 10B was pending before the Commissioner (Appeals); reopening proceedings initiated in respect of matters connected with such assessment were not sustainable in view of the third proviso to section 147. [S.10B, 148, 246A, Art. 226]
Vedanta Ltd. v. ACIT [2025] 170 taxmann.com 554 (Bom.)(HC)S.147: Reassessment-After the expiry of four years-Reasons recorded for reopening-Vague reasons relating to alleged unexplained credits, and the Assessing Officer subsequently sought to improve or supplement reasons while disposing of the assessee’s objections-Recorded reasons did not allege any failure on the part of the assessee to disclose material facts-Reopening notice and order rejecting objections were quashed and set aside.[S.68, 148, Art. 226]
Stock Holding Corporation of India Ltd. v. ACIT [2025] 178 taxmann.com 191 (Bom)(HC)S.147: Reassessment-After the expiry of four years-Cash sales-Unexplained money-Income already assessed substantively in another year-Reassessment notice and order disposing of the objection were quashed and set aside.[S. 69A, 148, Art. 226]
Sai Shirdi Constructions v. ITO [2025] 174 taxmann.com 750 (Bom) (HC)S.147: Reassessment-After the expiry of four years-Change of opinion-Reopening notice was held to be invalid and was quashed.[S. 40(a)(ia), 80P, 148 Art. 226]
Prithvi Apartments Co-operative Housing Society Ltd. v. ACIT [2025] 174 taxmann.com 654 (Bom)(HC)S. 147: Reassessment-After the expiry of four years-Tangible material-Information regarding undisclosed funds routed through tax-haven companies-Reopening valid.[S. 69A, Art. 226]
Macrotech Developers Ltd. v. DCIT [2025] 174 taxmann.com 56 /2026] 489 ITR 363 (Bom) (HC)S.147: Reassessment-After the expiry of four years-Expenditure incurred on gift articles-No failure to disclose material facts-Reopening quashed.[S. 37(1), 148, Art. 226]
Mapra Laboratories (P.) Ltd. v. UOI [2025] 173 taxmann.com 221 (Bom) (HC)S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Subsequent tax residency certificate-Reopening invalid.[S. 6, Art. 226]
Oxford University Press v. DCIT [2025] 171 taxmann.com 655 (Bom) (HC)S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment quashed.[S. 36(1)(vii), 148, Art. 226]
ICICI Bank Ltd. v. DCIT [2025] 171 taxmann.com 617 (Bom) (HC)S. 144C: Reference to dispute resolution panel-Draft assessment order-Final assessment order had been directly passed by a Faceless Officer without serving a draft assessment order on the assessee to enable it to approach the DRP; it was in clear violation not only of the provisions of section 144C but also of section 144B(1)(xxi) to (xxix) and thus, the final assessment order was set aside. [S. 144B(1)(xxi) Art. 226]
Barentz India (P.) Ltd. v. NFAC [2025] 179 taxmann.com 582 (Bom)(HC)