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THE HIGH COURT OF KARNATAKA
S.R.Krishna Kumar, J
Khoday India Limited – Appellant
Versus
The Principal Commissioner of Income Tax Bengaluru-4 – Respondent
| Table of Content |
|---|
| 1. petitioner's identity and nature of the application. (Para 1 , 2) |
| 2. arguments for quashing the notice under section 148. (Para 3 , 4) |
| 3. respondent's perspective on reopening assessments. (Para 5 , 6) |
| 4. analysis of the legality of notice and requirements for reopening. (Para 7) |
| 5. judicial interpretations on assessment procedures post-amendment. (Para 8 , 9) |
| 6. determining the boundary of valid assessment reopening. (Para 10) |
| 7. conditions for invoking reassessment provisions. (Para 14 , 15) |
| 8. outcome of the petition and orders of the court. (Para 18 , 19 , 20) |
ORAL ORDER
In this petition, petitioner seeks the following reliefs:
(a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari or order quashing the notice issued under section 148 in PAN:AAACK6734C dated: 30.3.2018 by Respondent No.3 marked as Annexure-K for the A.Y.2011- 12 as bad in law.
(b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari or order quashing the letter in F.No.ITO-W- 4(1)(2)/AAACK6734C/2018-19 dated:26.10.2018 issued by Respondent No.3 disposing of the legal objections raised by the petitioner for reopening of the assessment under section 147
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