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Case Law Details

Case Name : Mira Bhavin Mehta Vs ITO (Bombay High Court)
Appeal Number : Writ Petition No. 3246 of 2022
Date of Judgement/Order : 13/02/2024
Related Assessment Year :
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Mira Bhavin Mehta Vs ITO (Bombay High Court)

In a landmark judgment, the Bombay High Court in Mira Bhavin Mehta Vs Income Tax Officer (ITO) delved deep into the contentious issue of tax reassessment based on a change of opinion. This case provides pivotal insights into the interpretation and application of the Income Tax Act, 1961, particularly in the context of reassessment proceedings. The court’s decision not only illuminates the legal framework governing reassessment but also sets a significant precedent for future cases involving similar disputes.

Background of the Case

Mira Bhavin Mehta, the petitioner, filed a return of income for the Assessment Year (AY) 2018-19, which was subsequently selected for limited scrutiny concerning investments in immovable property and capital gains. Despite providing detailed submissions in response to various notices from the Income Tax Department, the petitioner was later confronted with a reassessment procedure initiated under Section 148 of the Act, challenging the nature and taxation of capital gains derived from a property transaction.

Legal Contestation and High Court’s Ruling

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