S. 148: Reassessment-Notice-Merger-Tribunal quashed the order-No specific direction for reassessment-Section 150 could not be invoked-Notice was time-barred and invalid under section 149.[S. 149, 150]

S. 144C : Reference to dispute resolution panel-Limitation-DRP’s proceedings was issued on 10-6-2022, uploaded in ITBA portal on 22-6-2022 and communicated to Assessing Officer on 4-7-2022, last date for passing impugned assessment order would have expired on 31-8-2022 and, thus, assessment order passed on 19-8-2022 was within period of limitation. [S.144C(13), Art. 226]

S. 144C : Reference to dispute resolution panel-Period of limitation-Date of uploading DRP order on ITBA Portal is to be considered as date of service to recipient and time for Assessing Officer to pass assessment order starts running from date of receipt of DRP order-Order was barred by limitation. [S.144C(13),153, 260A, 282]

S. 143(3): Assessment-Non-existent Oriental Bank of Commerce-Strictures-Prior intimation of merger and request for PAN cancellation-Since action had already been taken against Assessing Officer on administrative side, only token cost of Rs. 10,000 was imposed, payable to Gujarat State Legal Services Authority, instead of Rs. 1 crore proposed earlier for negligent assessment without independent verification and over-reliance on software systems. [Art. 226]

S. 139 : Return of income-Extension of due date—Date of filing audit report-Proposal for extension of return filing due date for auditable assessees for assessment year 2025-26 remained undecided and delay in e-filing utilities caused hardship, CBDT was directed to issue circular extending return filing due date to 30.11.2025 for assessment year 2025-26. [S.44AB, 119, Art. 226]

S. 139 : Return of income—Tax audit report—Specified date—Extension of due date—CBDT Circular No. 14 of 2025 extending only the “specified date” without extending the “due date” is contrary to Expln. (ii) to s. 44AB and legislative intent—There must statutorily remain a gap of one month between the tax audit report date and return filing due date—CBDT directed to extend due date for filing return to 30-11-2025 for assessees liable to furnish audit report for AY. 2025-26.[S. 44AB, 119, 139(1), 139(2), Art. 226]

S. 139 : Return of income-Tax audit report-Extension of due date-Technical glitches on e-filing portal-Delayed release / intermittent functioning of utilities-Sharp fall in number of tax audit reports filed as compared to earlier year-Extension granted for individual ITRs also relevant-Significant hardship to assessees and professionals justified judicial intervention-As an interim measure, due date for filing tax audit reports for A.Y. 2025-26 extended from 30-9-2025 to 31-10-2025. [S. 44AB, 119, Art. 226]

S. 132A : Powers-Requisition of books of account-Search and seizure-Cash and seizure of articles-Seizure of jewellery by Sate Survellance Team (SST) of District Election Officer and handing over to IT Department— Logistics company-Application for release of seized assets Consignments of jewellery seized by Static Surveillance Team under guidelines issued by Election Commission and handed over to Income-tax Department-Non-recording of satisfaction note-Reassessment notice was quashed-The application filed by the AT Jewellers was liable to be considered by the AO, i.e. Dy. CIT, Central-2.Apart from AT Jewellers, whoever is the consignee claiming ownership and release, may submit an application before the same AO-Writ petitions are allowed with a direction to the Dy. CIT, Central-2 to release the jewellery consignments-Cost of Rs.50000 was awarded in favour of all the writ petitioners payable by the respondents severally and jointly.[S. 127, 131,132,147, 148, Art. 226]

S. 132 :Search and seizure—Reason to believe-Three lockers-Jewellery and bullion worth in crores-Sufficiency of the information for forming the reasons to believe is cannot be examined in writ proceedings-Writ petition dismissed.[S. 132(1), 132(3), Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Delay in filing Form No 9A-Misprint contained in taxman publication-Delay was condoned-Directed to grant the exemption. [S.11(1)(a), 11(7), 119(2)(b), 139,Form 9A, Art. 226]