S. 147 : Reassessment –With in four years- Advance – Change of opinion – Notice and order disposing the objection was quashed. [S. 69A 148, Art. 226]
D.K. Realty India (P.) Ltd. v. ACIT [2023] 148 taxmann.com 468 / 292 Taxman 328 (Bom)(HC)S. 147 : Reassessment –With in four years- Advance – Change of opinion – Notice and order disposing the objection was quashed. [S. 69A 148, Art. 226]
D.K. Realty India (P.) Ltd. v. ACIT [2023] 148 taxmann.com 468 / 292 Taxman 328 (Bom)(HC)S. 147 : Reassessment–With in four years- Accommodation entries – Shell company – Deposit demonetized cash- Sales Borrowed satisfaction – Not independently applied the mind- Reassessment notice and order disposing the objection was quashed. [S. 69A, 143(1), 148, Art. 226]
B.U. Bhandari Autolines (P.) Ltd. v. ACIT [2023] 456 ITR 56/ 292 Taxman 195/ 331 CTR 240 (Bom)(HC)/Editorial : SLP of Revenue is dismissed on account of delay of 354 days as well as on merits . ACIT v. B. U. Bhandari Autolines Pvt. Ltd. (2025)472 ITR 1 /171 taxmann.com 130 (SC)S. 147 : Reassessment – With in four years – No tangible material – Business expenditure -Compensation- Provision for compensation – Pending for settlement – Reassessment is held to be bad in law. [S. 37(1), 145, 148, Art. 226]
PCIT v. NESCO Ltd. [2023] 291 Taxman 286 (Bom)(HC)S. 147 : Reassessment–With in four years- Depreciation–Change of opinion –Depreciation–License fee–No new information– Reassessment notice and order disposing the objection was quashed. [S. 32, 35AAB, 148, Art. 226]
Clear Media (India) (P.) Ltd. v. DCIT [2023] 150 taxmann.com 52 / 293 Taxman 108 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years- Co-operative Society-Deduction allowed- Change of opinion–Reassessment notice and order disposing the objection was quashed. [S. 80P(2)(1), 80P(2)(d), 148, 226]
Mumbai Postal Employees Co-operative Credit Society Ltd. v. ITO [2023] 149 taxmann.com 94 / 292 Taxman 492 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years – Co-operative societies – Reopening of assessment being a mere change of opinion was not justified–Reassessment notice and order disposing the objection was quashed. [S. 80P, 148, Art. 226]
Tahnee Heights CHS Ltd. v. ITO [2023] 458 ITR 585 /147 taxmann.com 335 / 292 Taxman 315 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years- Infrastructure Development-Audit objection -No failure to disclose material facts–Notice of reassessment based on Audit objection–Reassessment notice and order disposing of the objection was quashed. [S. 80IA(4), 115JB, 148, Art. 226]
Saurashtra Infra and Power Pvt. Ltd. v. Dy. CIT (2023) 451 ITR 51 / 149 taxmann.com 388 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years – Interest on funds collected–Issue pending before the Commissioner (Appeals)- Reassessment notice and order disposing the objection was quashed. [S. 80IA, 148, 250, Art. 226]
Nuclear Power Corporation of India Ltd. v. DCIT [2023] 151 taxmann.com 537 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years – Set-off of long term capital loss against long term capital gain – No failure to disclose material facts–No power of review – Reassessment notice and order disposing the objection was quashed. [S. 74, 143(3), 148, Art. 226]
Noshir Darabshaw Talati v. ACIT [2023] 150 taxmann.com 16 (Bom)(HC)S. 147 : Reassessment–After the expiry of four years–Commission payment – No failure to disclose material facts-No new tangible material to justify reopening, reassessment proceedings were nothing but a case of change of opinion,- Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]
Jetair (P.) Ltd. v. DCIT [2023] 148 taxmann.com 185 (Bom)(HC)