Ser. Ltd. v. DCIT

232 Taxmann 702High Court2015#4633 most cited

What is Ser. Ltd. v. DCIT authority for?

Reopening of assessment beyond four years requires tangible material beyond a mere change of opinion. The Assessing Officer must have fresh tangible material to justify reopening beyond the initial assessment.

26

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Ser. Ltd. v. DCIT · section 147 · beyond four years · fresh tangible material · mere change of opinion · reassessment · notice u/s 148 · reasons to believe · Section 151(2)

Issues it is cited on

Judgments citing Ser. Ltd. v. DCIT

AMBAJI AVENUES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER, WARD-9(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3922/MUM/2024[2012-13]Status: DisposedITAT Mumbai25 Oct 2024AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailassessment Year: 2012-13 Ambaji Avenues Private Limited Income Tax Officer- 9(1)(2), Mumbai A-109, Akshay Mittal Indl. Premises, M.V. Road, Sanjay Vs. Building No. 5, Andheri (W), Mumbai-400059. Pan: Aajca 8264 G (Appellant) (Respondent) Present For: Assessee By : Shri Ramesh Kumar Malpani Revenue By : Shri Manoj Kumar Sinha, Sr. Dr Date Of Hearing : 09.09.2024 Date Of Pronouncement : 25.10.2024 O R D E R Per Amarjit Singh: This Appeal Of The Assessee For The Assessment Year 2012-13 Is Directed Against The Order Dated 19.06.2024 Passed By The Ld. Commissioner Of Income-Tax (Appeal), Nfac, Delhi. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Ramesh Kumar MalpaniFor Respondent: Shri Manoj Kumar Sinha, Sr. DR
Section 143(3)Section 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “A”, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER Assessment Year: 2012-13 Ambaji Avenues Private Limited Income Tax Officer- 9(1)(2), Mumbai A-109, Akshay Mittal Indl. Premises, M.V. Road, Sanjay Vs. Building No. 5, Andheri (W), Mumbai-400059. PAN: AAJCA 8264 G (Appellant) (Respondent) Present for: Assessee by : Shri Ramesh Kumar Malpani Revenue by : Shri Manoj Kumar Sinha, Sr. DR Date of Hearing : 09.09.2024 Date of Pronouncement : 25.10.2024 O R D E R PER AMARJIT SINGH, ACCOUNTANT MEMBER: This appeal of…

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