https://www.taxtmi.com/caselaws?id=761104 The Gujarat HC quashed a reassessment notice issued u/s 148 of the Income Tax Act. The assessee had fully disclosed all material facts during original assessment proceedings, including details of immovable property transactions in response to s 142(1) notice. The Assessing Officer accepted the return and passed assessment order u/s 143(3). The court found the reassessment notice was based on borrowed satisfaction without independent application of mind, containing wrong figures regarding property transactions. Since there was no failure to disclose material facts and the notice was issued beyond four years, it lacked jurisdiction under proviso to s 147. The notice was quashed in favor of the assessee. en-us Mon, 14 Oct 2024 00:00:00 +0530 Tue, 05 Nov 2024 07:38:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761104 The Gujarat HC quashed a reassessment notice issued u/s 148 of the Income Tax Act. The assessee had fully disclosed all material facts during original assessment proceedings, including details of immovable property transactions in response to s 142(1) notice. The Assessing Officer accepted the return and passed assessment order u/s 143(3). The court found the reassessment notice was based on borrowed satisfaction without independent application of mind, containing wrong figures regarding property transactions. Since there was no failure to disclose material facts and the notice was issued beyond four years, it lacked jurisdiction under proviso to s 147. The notice was quashed in favor of the assessee. Case-Laws Income Tax Mon, 14 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761104