The Gujarat High Court quashed a reassessment notice issued under Section 148 after finding that a loose paper seized from a third party did not establish any live link with the assessee. The Court held that vague and non-specific material cannot justify reopening of assessment.
The Gujarat High Court held that reassessment cannot be sustained merely because of high-value bank transactions without evidence of escaped income. It quashed the Section 148 notices and Section 148A(3) orders after finding that the transactions were recorded in audited books and adequately explained.
The Gujarat High Court quashed the reinitiated penalty proceedings after the Assessing Officer failed to pass a fresh order within the 12-week period fixed by the Court. It held that non-compliance with the earlier judicial directions warranted setting aside the show-cause notices.
The Gujarat High Court held that once the Resolution Plan was approved under Section 31 of the IBC, all tax liabilities not forming part of the plan stood extinguished. It therefore quashed the reassessment notice and the order under Section 148A(d).
The Gujarat High Court set aside the reassessment after finding that the Assessing Officer failed to provide specific reasons for treating bank credits as unexplained cash credits under Section 68. The matter was remanded for fresh adjudication.
The Gujarat High Court quashed the reassessment notice after finding that the seized inquiry register did not establish any direct or indirect connection with the taxpayer. It held that reopening based on vague material and presumptions was unsustainable.
The Gujarat High Court held that after considering the ledger entries correctly, the alleged escaped income was only ₹45 lakh, below the threshold under Section 149(1)(b). As the reopening was beyond the prescribed limitation, the order under Section 148A(d) was quashed.
Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey proceedings under Section 133A, not a search under Section 132. Court ruled that Section 96(a)(i) cannot be applied beyond its express wording.
The Gujarat High Court held that reassessment under Section 148 cannot be based on third-party loose papers that fail to establish a live link with the assessee. The Court quashed the notice as the material was vague and unrelated to the petitioner’s transaction.
The Gujarat High Court set aside the reassessment proceedings after holding that they were founded on an undated and uninvestigated complaint without any direct link to the petitioner. The Court found the reopening to be based on conjectures and surmises.