S.148: Reassessment-Notice-Barred by limitation-Notice and order is quashed. [S.149(1)(b), Art. 226] Assessment year 2015-16-Barred by limitation (A.Y. 2015-16)
20 Media Collective Pvt. Ltd.v Pr. ACIT (Bom) (HC)(UR)S.148: Reassessment-Notice-Barred by limitation-Notice and order is quashed. [S.149(1)(b), Art. 226] Assessment year 2015-16-Barred by limitation (A.Y. 2015-16)
20 Media Collective Pvt. Ltd.v Pr. ACIT (Bom) (HC)(UR)S. 148 : Reassessment –Notice-Dead person-Notice and order is void ab initio [S. 147, Art. 226]
Mary Gene Gracious v. ITO (Bom)(HC)(UR)S. 147 : Reassessment –With in four years-Bad debt –Advances written off-Change of opinion-Reassessment notice and order disposing the objection is quashed and set aside. [S.36(1)(vii), 142(1), 143(3), Art. 226]
Changepond Technologies (P.) Ltd. v. ACIT (2024) 301 Taxman 613 (Mad.)(HC)S. 147: Reassessment-Provision of certain amount towards restatement of liability in foreign currency-Reassessment is valid Finding of fact given by Tribunal cannot be disturbed in appeal before the High Court.[S.37(1), 148, 254(1), 260A]
Costal Energy (P.) Ltd. v. Dy. CIT (2024) 301 Taxman 51 (Mad.) (HC)S. 147 : Reassessment –With in four years-Purchase and sale of land-Audit objection-Business income or capital gains-No fresh, tangible information-Reassessment notice and order disposing the objection is quashed.[S.28(i), 45, 148, Art. 226]
Nanubhai Vashrambhai Ramolia v. ACIT (2024) 301 Taxman 199 (Guj)(HC)S. 147 : Reassessment-Long term capital gain-Limited scrutiny-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S.54F,143(3), 148, Art. 226]
Hareshkumar Bhupatbhai Panchani v. ITO (2024) 301 Taxman 363 (Guj)(HC)S.147: Reassessment-After the expiry of four years-Capital asset –Agricultural land-Agricultural and situated beyond municipal limits, same did not come within ambit of section 2(14)(iii)(a)-No capital gain is liable to be taxed.[S. 2(14)(iii)(a), 45, 143(3), 144, 148, Art. 226]
Dinesh Singla v. ACIT (2024) 301 Taxman 432 (P&H)(HC)S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-G.P rate of unrecorded transactions were recorded at 7.5% as against G.P rate of 12.5 % in respected recorded transactions-Reassessment notice and order disposing the objection is quashed. [S.143(3), 148, Art. 226]
Susheel Kumar Shankarlal v. ITO (2024) 301 Taxman 61 (MP)(HC)S.147: Reassessment-After the expiry of four years-Bogus bills-Accommodation entries-Book profit-Adding the amount calculated by Assessing Officer towards escaped income amount computed under ordinary provision of Act amounted would be less than the amount paid as per book profit-Notice and order disposing the objection is quashed. [S.115JB,143(3), 148, Art. 226]
Adani Wilmar Ltd. v. ACIT (2024) 301 Taxman 84 (Guj.)(HC)S.147: Reassessment-After the expiry of four years-notice under section 148 issued to examine the issue already verified during the course of assessment proceedings-No failure on the part of assessee-Notice is invalid.[S.28(i), 148, Art.226]
Aavkar Projects (Tragad LLP) v. Dy. CIT (2024) 301 Taxman 122 (Guj.)(HC)