This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
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S. 149: Reassessment-Time limit for notice-High Court held that where the period of six years from the end of the relevant assessment year 2016-17 expired on 31.03.2023, notice issued thereafter on 31.03.2024 was barred by limitation-SLP of revenue dismissed. [S. 148, Art. 136]

ACIT v. Mohd Athar Anjum (2026) 310 Taxman 659 (SC) Editorial : Mohd Athar Anjum v.ACIT(2026) 186 taxmann.com 12 (Delhi)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Constitutional validity-Notice issued to the Attorney General of India-Arguable questions were raised in the petition; operation of the notice dated 30-3-2025 under section 148 was stayed. [S.148, Explanation 2, Clause (c), Art. 14, 226]

G. M. Polyplast Ltd. v. ACIT (2026) 310 Taxman 542 (Bom.)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice-After the expiry of four years-Notice and consequential orders are quashed and set aside. [S. 144C(1), 147, 148, 148A(b), 148A(d), Art. 226]

Gulbrandsen (P.) Ltd. v. Dy. CIT (2026) 310 Taxman 188 (Guj)(HC)

S.148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained money-Cross-examination-mere denial/non-completion of cross-examination of said third party did not vitiate order under section 148A(d)-Opportunity of cross-examination must be provided before passing the assessment order. [S.69, 132(4), 147, 148, 148A(b), 148A(d), Art. 226]

Vishnu Highrise (P.) Ltd. v. UOI (2026) 310 Taxman 260 (Cal)(HC)

S.148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Trading of gold, silver, diamond and bullion-High-risk transactions and a GST show cause proposing registration cancellation for ineligible ITC-Reassessment notice and consequential orders are quashed and set aside.[S.69A, 148, 148A(b), 148A(d), Art. 226]

Piyush Mafatlal Shah v. ITO (2026) 310 Taxman 246 (Guj)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Development agreement for acquiring development rights funded through unsecured loan from its director-No failure to disclose material facts-Reassessment notice and consequential orders were quashed. [S.68, 143(2), 148, 148A(b), 148A(d), Art. 226]

Laxmi Infra Developers Ltd. v. ACIT (2026) 310 Taxman 321 (Guj)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Scientific research expenditure-Change of opinion-The power to reexamine cannot be exercised from time to time-Reassessment notice and consequential orders were quashed.[S.35(2AB),143(3), 147, 148, 148A(b), 148A(d), Art. 226]

Gujarat Metal Cast Industrial (P.) Ltd. v. ACIT (2026) 310 Taxman 33 (Guj)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Capital gains-Change of opinion-Notice and consequential orders were quashed and set aside.[S.54F, 143(3), 148, 148A(b), 148A(d), Art. 226]

Dignesh Pramukhlal Patel v. ACIT (2026) 310 Taxman 536 (Guj.)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Fictitious losses-Mutual fund-Notice and consequential orders were quashed-SLP of revenue dismissed. [S. 148, 148A(b), 148A(d), Art. 136]

PCIT v. Jyoti Bhatia (2026) 310 Taxman 664 (SC) Editorial:. Jyoti Bhatia v.ACIT(2026) 185 taxmann.com 915 (Delhi)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Co-operative societies-Interest income on fixed deposit kept with cooperative bank-SLP of revenue was dismissed on account of delay of 225 days in filing SLP [S.80P(2)(d), 148, 148A(b), 148A(d), Art. 136]

ACIT v. Kutch District Cooperative Milk Producers Union Ltd. (2026) 310 Taxman 175 (SC) Editorial: Kutch District Cooperative Milk Producers Union Ltd v. ACIT (2025) 173 taxmann.com 495 (Guj)(HC)