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Seahorse Mercantile Company (P.) Ltd. v. ITO (2025) 304 Taxman 511 (SC) Editorial : Seahorse Mercantile Company (P.) Ltd. v. ITO (2025) 172 taxmann.com 699 (Bom)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Alternative remedy-High Court held that since Assessing Officer had passed well detailed order after rebutting assessee’s contentions, assessee should be directed to adopt alternate remedy of appeal against assessment order-SLP filed by assessee against the order of High Court was dismissed [S. 143(3), 148, 148A(b), 148A(d), Art. 136]

Seahorse Mercantile Company (P.) Ltd. v. ITO (2025) 304 Taxman 277 (SC) Editorial : Seahorse Mercantile Company (P.) Ltd. v. ITO (2025)172 ITR 162 (Bom)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Order of High Court set aside in view of UOI v. Rajeev Bansal [2024]301 Taxman 238/469 ITR 46(SC) final assessment order was quashed only for purpose of enabling assessee to raise all objections and contentions vis-a-vis impugned notices.[S. 148, 148A(b), 148A(d), Art. 136]

Monish Gajapati Raju Pusapati v. AUITD (2025) 304 Taxman 382/344 CTR 165 / 248 DTR 17 (Delhi)(HC)

S. 148 : Reassessment-Notice-Non application of mind-Notice was quashed. [S. 135A,292B, Art. 226]

Amjad Ahmed Shaikh v. ITO (2025) 304 Taxman 377 (Bom.)(HC)

S. 148 : Reassessment-Notice -Dead person-Department had knowledge of demise of assessee -Not bind legal representative- Notice and order quashed.[S.147, 148A(b), 148A(d), Art. 226]

Dy. CIT v. Sterlite Technologies Ltd. (2025) 304 Taxman 345 (SC) Editorial : Sterlite Technologies Ltd v.Dy.CIT (2023) 152 taxxmann.com 381/ (2024) 462 ITR 457 (Bom)(HC)

S. 148 : Reassessment -Amalgamation-Notice issued to non-existent company- Order is non-est and void- SLP of revenue dismissed. [S. 147, Art. 136]

Osstem Implant India (P.) Ltd. v. Dy. CIT (2025) 304 Taxman 686 (Bom.)(HC)

S. 147 : Reassessment -With in four years- Cash credits-Cash deposits-Demonetisation-Re assessment notice was held to be justified-Writ petition was dismissed. [S. 68, 148, Art. 226]

PCIT v. East Delhi Leasing (P.) Ltd. (2025) 304 Taxman 705 (Delhi)(HC)

S. 147 : Reassessment -Cash credits-Reason to believe-Suspicious Transaction Report (STR) -Burden of proof-Tribunal could not have applied the principle enunciated by court in criminal case to discharge of burden of proof beyond reasonable doubt-Order of Tribunal set aside. [S. 68, 148, 260A]

GlaxoSmithKline Pharmaceuticals Ltd. v. ACIT (2025) 304 Taxman 350 (Bom.)(HC)

S.147: Reassessment-After the expiry of four years-Sale promotion expenses incurred on doctor -Since there was no failure on part of assessee to disclose fully and truly all material facts necessary for assessment, reopening notice was quashed.[S. 143(3), 148, Art. 226]

Madhuri Sameer Gokhale v. NFAC (2025) 304 Taxman 359 /(2026) 349 CTR 411 (Bom.)(HC)

S.147: Reassessment-After the expiry of four years- Faceless Assessment Standard Operating Procedure -Natural justice-No fresh tangible material-Reassessment notice and order disposing the objection was quashed-Cash credits [S. 68, 144, 144B(6)(xi), 148, Art. 226]

Tata Communications Ltd. v. Dy. CIT (2025) 304 Taxman 476 (Bom)(HC)

S.147: Reassessment-After the expiry of four years- Transfer pricing-Arms’ length price-Avoidance of tax-International transaction-Gurantee fees- Pending before Tribunal- Court held that the Assessing Officer was debarred from initiating reassessment proceedings on that very issue -Re assessment notice and order disposing the objection was quashed. [S.92C, 143(3), 148, Art. 226]