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. 151: Reassessment-Sanction for issue of notice-Approval granted after expiry of three years-SLP delay of 411 days-SLP of revenue was dismissed on account of delay as well as on merits. [S.148, 148A(b), 148A(d), 149(1)(b), Art. 136]

ACIT, IT v. LinkedIn Singapore Pte. Ltd. (2025) 307 Taxman 524 (SC) Editorial: Linkedin Singapore PTE. Ltd. v. ACIT(IT) [2025] 179 taxmann.com 412 (Bom)(HC)

S. 150: Assessment-Order on appeal-Survey-Direction issued by the CIT(A) beyond the limitation period-No assessment or reassessment could be made as the time period prescribed under section 149 had already expired-Assessing Officer could not have reopened assessment in compliance with said direction.[S. 133A, 148, 149, 150(1),250, Art. 226]

Shubh Buildcon v. ITO (2025) 307 Taxman 181 (Guj.)(HC)

S. 149: Reassessment-Time limit for notice-Concession given by Additional Solicitor General (ASG)-Notice under section 148 dated 5-4-2022, and all consequential orders/notices were to be quashed.[S. 148, 149(1)(b),151, Art. 226]

Cherian Nallathu Abraham Annamma v. ITO, IT (2025) 307 Taxman 367 (Bom.)(HC)

S. 149: Reassessment-Time limit for notice-Concession made by Additional Solicitor General before the Supreme Court as recorded in Rajeev Bansal-Notice being barred by limitation was to be dropped, and consequently reassessment order, demand notice and penalty notices were quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]

Verjinia Foods Ltd. v. ITO (2025) 307 Taxman 563 (Bom.)(HC)

S. 149: Reassessment-Time limit for notice-Surviving period-date of earlier notice under section 148 read with TOLA up to 30-06-2021, last permissible date for issuance of reassessment notice under section 148 would be 18-06-2022-Notice dated 27-07-2022 issued under section 148 having been issued beyond surviving time was invalid [S. 148, 148A(b), 148A(d), Art. 226]

Opera Exports (P.) Ltd. v. ACIT (2025) 307 Taxman 65 (Guj.)(HC)

S. 149: Reassessment-Time limit for notice-Notice dated 30-8-2022 issued under section 148 being issued beyond ‘surviving time’ and hence invalid.[S. 148, 148A(b), 148A(d), Art. 226, Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA).]

Ashitkumar Satishchandra Patel v. ITO (2025) 307 Taxman 538 (Guj.)(HC)

S. 149: Reassessment-Time limit for notice-Order of the High Court was affirmed-SLP of the revenue was dismissed as time-barred. [S. 148, 148A(b), 148A(d), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 136]

UOI v. Krishna Fashion World (2025) 307 Taxman 7 (SC) Editorial: Virendra Ship Recyclers LLP v. ACIT (2025) 170 taxmann.com 588 (Bom)(HC)

S. 149: Reassessment-Time limit for notice-SLP delay of 800 and 467 days-SLP of revenue dismissed on account of delay.[S. 148,148A(b) 148A(d), Art. 136]

ITO v. Dhara Varun Shah (2025) 307 Taxman 11 (SC) Editorial: Dhara Varun Shah v. ITO [2023] 151 taxmann.com 558 (Guj)(HC)

S. 149: Reassessment-Time limit for notice-last date for service of notice and initiating proceedings under section 148 under unamended provisions was coming to an end on 31-3-2021, but notices had been issued from the office of the Department either on 1-4-2021-SLP of revenue dismissed. [S. 148, Art. 136]

ITO v. Medwin Hospital Services (2025) 307 Taxman 9 (SC) Editorial: Kalyan Chillara v. DY.CIT [2024] 167 taxmann.com 500 (Telangana)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Opportunity of hearing-Notice and order were quashed and set aside. [S. 144B, 148A(b) 148A(d), 151A, Art. 226.]

Mallesh Goud Donkeni v. ITO (2025) 307 Taxman 190 (Telangana)(HC)