Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Ornate Spaces (P.) Ltd v. Dy.CIT (2026) 185 taxmann.com 422 (Bom) HC) Editorial : SLP of revenue dismissed, Dy. CIT v. Ornate Spaces (P.) Ltd. (2026) 310 Taxman 405 (SC)

S. 148 : Reassessment-Notice-Merger-Waiver of tax liability-Assessment year 2021-22-Assessee-corporate debtor underwent insolvency resolution and a revised assessee underwent insolvency, and a resolution plan approved by NCLT extinguished all prior tax liabilities-Assessing Officer issued notices under sections 148 and 142 for a period prior to approval-No belated claims could be raised after approval of resolution plan-High Court quashed the notice and consequential orders. [S. 147, the Insolvency and Bankruptcy Code, 2016, S. 31, Art.226]

Dy. CIT v. Ornate Spaces (P.) Ltd. (2026) 310 Taxman 405 (SC) Editorial: Ornate Spaces (P.) Ltd v.Dy.CIT (2026) 185 taxmann.com 422 (Bom)(HC)

S. 148: Reassessment-Notice-Merger-High Court quashed the notice and consequential orders; SLP of revenue quashed. [S. 147, the Insolvency and Bankruptcy Code, 2016, S. 31, Art. 136]

Dy. CIT v. Hewlett Packard Financial Services (India) (P.) Ltd. (2026) 310 Taxman 2 (SC) Editorial : Dy. CIT v. Hewlett Packard Financial Services (India) (P.) Ltd(2026) 183 taxmann.com 596 (Karn)(HC)

S. 148: Reassessment-Notice-Failure to dispose of objection-Reassessment notice and consequential orders are bad in law-SLP of revenue dismissed. [S. 147, Art. 136]

CIT, LTU v. Shell India Markets (P.) Ltd. (2026) 310 Taxman 1 (SC) Editorial: CIT, LTU Shell India Markets (P.) Ltd(2025) 174 taxmann.com 349 (Bom)(HC)

S. 148: Reassessment-Notice-Merger-Initiated to the Assessing Officer-Assessment and order were issued in the name of a non-existent entity-High Court quashed the notice and assessment-SLP of revenue was dismissed. [S. 143(3), 292B, Art. 136]

Shardaben Hashmukhbhai Patel v. ITO (2026) 310 Taxman 706 (Guj)(HC)

S. 147: Reassessment-Co-owner-Reopening of assessment in case of mother of assessee, who was co-owner of land in question, had already been quashed and set aside; jurisdictional notice issued under section 148, reassessment order passed under section 147 and penalty notice issued under section 271DA were quashed and set aside. [S.271DA, 148, Art. 226]

PCIT v. NTPC Ltd. (2026) 310 Taxman 54 (Delhi)(HC)

S. 147: Reassessment-Industrial undertakings-Infrastructure development-Audit objection-Order of the Tribunal quashing the reassessment was affirmed. [S.80IA, 148, 260A]

Gaurav Santramdas Varma v. ACIT (2026) 310 Taxman 693 (Guj)(HC)

S.147: Reassessment-Unexplained investments-Purchase of land-On money-Search-Seized inquiry register entry did not establish any live nexus with assessee; reopening notice I and consequential orders are quashed. [S. 69,132,148,292C, Art. 226]

Aditya H.Patel v. ITO (2026) 310 Taxman 530 (Guj.)(HC)

S. 147:Reassessment-Cash credits-Agricultural land-Loose papers seized-No nexus-Reassessment notice and order disposing of the objection was quashed. [S. 68, 148, Art. 226]

Dy. CIT v. Venus Infrastructure and Developers (P.) Ltd. (2026) 310 Taxman 490 (SC) Editorial: Venus Infrastructure and Developers (P.) Ltd v. CIT (2026) 185 taxmann.com 423 (Guj) HC)

S.147: Reassessment-Housing projects-Failure to complete the housing project-Reassessment was quashed and set aside-SLP of revenue dismissed.[S.80IB(10), 148, Art. 136]

ITO v. Amitkumar Chandulal Rajani (2026) 310 Taxman 575 (SC) Editorial: Amitkumar Chandulal Rajani v.ITO (2025) 173 taxmann.com 32/ (2026) 486 ITR 230 (Guj) HC)

S.147: Reassessment-AO recorded reasons mechanically on information received from Investigation Wing-Unexplained money-Search-No direct nexus-Reassessment notice and order disposing of the objection were quashed and set aside-Order of High Court affirmed-SLP of revenue dismissed. [S.69A, 148, 151, Art. 136]