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. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained expenditure-Order of High Court affirmed-SLP of revenue dismissed. [S.69C, 148, 148A(b), 148A(d), Art. 136]

ACIT v. Vivo Mobile India (P.) Ltd. (2026) 310 Taxman 267 (SC) Editorial : Vivo Mobile India (P.) Ltd v ACIT (2025) 171 taxmann.com 657 (Delhi) (HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Purchase and sales-The assessee had dealt with information supplied to it by the revenue and had meticulously satisfied the data by comparing it with books of account-Reassessment notice and consequential orders were quashed by High Court-SLP of revenue dismissed. [S. 68, 148, 148A(b), 148A(d), Art. 136]

ITO v. R.D. Diamond (2026) 310 Taxman 493 (SC) Editorial : R.D. Diamond v.ITO (2026) 309 Taxman 136 (Guj)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Merged entity-Cash credits-Non-application of mind-PAN number was deactivated-Reassessment notice and consequential orders are quashed-SLP of revenue is dismissed. [S. 148, 148A(b), 148A(d), Art. 136]

Dy. CIT v. Rasna (P.) Ltd. (2026) 310 Taxman 660 (SC) Editorial : Rasna (P) Ltd v.Dy.CIT (2026) 185 taxmann.com 987 (Guj)(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-[S. 143(3), 260A, 292B]

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

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

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. 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]

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

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

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