https://www.taxtmi.com/caselaws?id=752654 The Bombay HC dismissed a review petition challenging the validity of reopening assessment under Section 148A. The petitioner argued that due to a technical portal glitch preventing the Assessment Officer from seeing the filed return and request for reasons, the order violated binding precedents in Ashish Agarwal and G.K.N. Driveshafts cases. The HC held that Ashish Agarwal precedent did not apply since the Section 148 notice was issued before 01.04.2021, and G.K.N. Driveshafts did not establish that bona fide system errors render entire proceedings illegal. The court found no error apparent on record warranting review, noting the petitioner's submissions sought impermissible reappreciation of merits rather than valid review grounds. en-us Wed, 08 May 2024 00:00:00 +0530 Tue, 14 May 2024 08:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752654 The Bombay HC dismissed a review petition challenging the validity of reopening assessment under Section 148A. The petitioner argued that due to a technical portal glitch preventing the Assessment Officer from seeing the filed return and request for reasons, the order violated binding precedents in Ashish Agarwal and G.K.N. Driveshafts cases. The HC held that Ashish Agarwal precedent did not apply since the Section 148 notice was issued before 01.04.2021, and G.K.N. Driveshafts did not establish that bona fide system errors render entire proceedings illegal. The court found no error apparent on record warranting review, noting the petitioner's submissions sought impermissible reappreciation of merits rather than valid review grounds. Case-Laws Income Tax Wed, 08 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752654