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<h1>Bombay HC stays IT Notice reopening 2012-13 assessment under Sec 148</h1> <h3>Asian Satellite Broadcast Pvt. Ltd. Versus Income Tax Officer Circle 6 (1) (3) & Others</h3> The Bombay High Court granted an ad-interim stay on a Notice issued by the Deputy Commissioner of Income Tax to re-open an Assessment for the Assessment ... Reopening of assessment u/s 147 - Notice issued beyond a period of four years from the end of the relevant Assessment Year - HELD THAT:- It is the Petitioner’s case that the facts which forms the basis of reasons to believe the income chargeable to tax were completely disclosed. Moreover, it was also subject matter of consideration during the regular Assessment Proceedings. Thus, it is clear case of change of opinion. Therefore, without jurisdiction. As none appears for the Respondent, Registry is directed to issue a notice to the Respondent, returnable on 27th November, 2019. Humdust permitted. The High Court Bombay High Court judgment challenges a Notice dated 22nd March, 2019 issued by the Deputy Commissioner of Income Tax under Section 148 of the Income Tax Act, 1961 to re-open an Assessment for the Assessment Year 2012-13. The Petitioner argues that the impugned notice is a clear case of change of opinion and lacks jurisdiction. The Court directs a notice to the Respondent returnable on 27th November, 2019 with an ad-interim stay on the impugned notice.