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.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]

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

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

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-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]

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-Unexplained investments-Investment in shares-Interest on borrowings-Security premium-Reassessment was quashed by the High Court-SLP is dismissed on account of delay of 498 days. [S. 14A, 69, 148, Art. 136]

Dy. CIT v. J.M. Financial Ltd. (2026) 310 Taxman 94 (SC) Editorial : J.M.Financial Ltd v.Dy.CIT (2024) 159 taxmann.com 740 (Bom)(HC) (Bom) (HC)

S.147 : Reassessment-Cash credits-High Court held that where information regarding assessee’s trades in shares was already available on record at the time of original assessment, reopening of assessment on said ground was invalid as it was not reason to believe but reason to suspect-SLP of revenue dismissed. [S. 68, 148, Art. 136]

PCIT v. Pradip Kumar Jajodia (2026) 310 Taxman 665 (SC) Editorial : PCIT v. Pradip Kumar Jajodia (HUF),(2026) 186 taxmann.com 193 (Cal)(HC)

S.147: Reassessment-After expiry of four years-No failure to disclose material facts-Change of opinion-Dividend from trust-Investment allowance wrongly claimed-Reopening invalid-SLP of revenue dismissed. [S. 2(22)(e), 10(34), 32AC, 115-O, 143(3), 148, Art.136]

ACIT v. Bharat Petroleum Corporation Ltd. (2026) 310 Taxman 89 (SC) Editorial : Bharat Petroleum Corporation Ltd v. ACIT(2025) 176 taxmann.com 103/ 478 ITR 358 (Bom)(HC)

S. 145: Method of accounting-Mercantile-Accrual-Time share membership fees-Matching principle-Membership fee received upfront could be deferred and recognised as income over tenure of membership contract, applying matching principle, notwithstanding mercantile system and absence of express statutory provision to defer revenue, and despite separate collection of annual maintenance and utility charges-Order of tribunal affirmed. [S. 4, 5, 28(i), 260A]

CIT, LTU v. Mahindra Holidays and Resorts (India) Ltd. (2026) 310 Taxman 677 (Mad)(HC)

S. 144C: Reference to dispute resolution panel-Final assessment order could not be treated as a draft assessment order, nor could the defect be cured by remanding the matter to the Assessing Officer for passing a fresh draft assessment order-Order was quashed. [S.143(3), 144B(1)(xxi), Art. 226]

Hansgrohe India (P.) Ltd. v. ACIT (2026) 310 Taxman 446 (Bom)(HC)

S. 144B: Faceless Assessment-Non-compliance with mandatory procedure-Draft assessment order-Assessment order was quashed and set aside. [S.144B(1)(xvi), Art. 226]

Ishwarlal Dahyalal Bauva v. NFAC(2026) 310 Taxman 316 (Bom)(HC)