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In these Writ Petitions, the petitioner has challenged the impugned notices dated 30.03.2015 & 30.03.2016 issued by the respondent under Section 148 of the Income Tax Act, 1961, to re-open the completed assessments for the Assessment Years 2009-10 and 201011 and consequential impugned communications dated 14.12.2015 and 28.11.2016 for the respective Assessment Years.

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Sec. 80IB & 147 of Income Tax Act, 1961— Reassessment - A mere change in opinion of an Assessing Officer does not clothe an Assessing Officer with the jurisdiction or power to reopen the assessment under Section 148 of the Income Tax Act, 1961 for the purpose of proviso to Section 147 of the Income Tax Act, 1961.INTERNATIONAL FLAVOURS AND FRAGRANCES INDIA PRIVATE LIMITED [2020] 315 CTR 448 (MAD)