Judgement

The Gujarat High Court has held that where an assessment has been completed under Section 143(3) it cannot be reopened merely on a change of opinion. 


High Court Rules Reassessment Notice under Section 148 Cannot Be Issued on Mere Change of Opinion

The Gujarat High Court has quashed a show cause notice, order under Section 179 holding that the Income Tax Department failed to provide reasonable opportunity of hearing

High Court Quashes Section 179 Proceedings Against Directors for Lack of Reasonable Opportunity 

Reassessment set aside as issues were already scrutinized and no fresh material existed for reopening.

High Court Quashes Reassessment Based on Mere Change of Opinion After Scrutiny

Reassessment invalid as reopening relied solely on presumptions without evidence against the assessee company.

High Court Quashes Reassessment Based on Presumed On-Money from Sister Concern

Reassessment invalid as recorded reasons related to an unrelated entity, not the petitioner company.

High Court Quashes Section 148 Notice Based on Wrong Assessee's Investigation Report

The Gujarat High Court has quashed a reassessment notice issued under Section 148  after holding that the AO wrongly invoked Section 55A(a) 


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High Court Rules Reassessment Notice under Section 148 Cannot Be Issued on Mere Change of Opinion

High Court Quashes Section 179 Proceedings Against Directors for Lack of Reasonable Opportunity

High Court Quashes Reassessment Based on Mere Change of Opinion After Scrutiny

High Court Quashes Reassessment Based on Presumed On-Money from Sister Concern

High Court Quashes Section 148 Notice Based on Wrong Assessee's Investigation Report

High Court Quashes Reassessment Notice Based on Retrospective Application of Section 55A Amendment