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Gujarat High Court

Section 148 Reopening Set Aside as Loose Paper Dated After Sale cannot Justify Reassessment

June 25, 2026 204 Views 0 comment Print

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.

Gujarat HC Sets Aside Reopening as High-Value Bank Credits Alone Cannot Justify Reassessment

June 25, 2026 444 Views 0 comment Print

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.

Gujarat HC Quashes Section 271D SCNs as12-Week Deadline Was Missed

June 23, 2026 348 Views 0 comment Print

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.

Income Tax Reopening Quashed as Section 31 of IBC Barred Fresh Tax Proceedings: Gujarat HC

June 23, 2026 282 Views 0 comment Print

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).

Gujarat HC Quashes Assessment as Section 68 Addition Was Made Without Reasons

June 23, 2026 294 Views 0 comment Print

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.

Section 148 Notice Quashed as Seized Document Had No Link With Taxpayer: Gujarat HC

June 23, 2026 360 Views 0 comment Print

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.

Gujarat HC Quashes Reassessment as Alleged Escaped Income Fell Below ₹50 Lakh Threshold

June 23, 2026 156 Views 0 comment Print

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.

Vivad se Vishwas Benefit Allowed as Assessment Was Based on Survey, Not Search: Gujarat HC

June 23, 2026 99 Views 0 comment Print

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.

Reassessment Quashed as Third-Party Loose Papers Had No Live Link with Assessee: Gujarat HC

June 21, 2026 273 Views 0 comment Print

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.

Gujarat HC Quashes Reassessment as Reopening Was Based on Unverified Complaint

June 21, 2026 459 Views 0 comment Print

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.

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