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 investments-Interest income-Failure to consider the reply-Matter remanded to the Assessing Officer. [S.69, 143(3), 148, 148A(b), 148A(d), Art. 226]

Vivek Kumar v. ITO (2025) 302 Taxman 96 (Delhi)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued under section 148 is treated as notice under section 148A(b)-Directed to dispose the objection in terms of UOI v. Rajeev Bansal [2024] 301 Taxman 238 (SC).[Art. 136]

ITO v. Ashish Acharatlal Varaiya (2025) 302 Taxman 183 (SC) Editorial : Ashish Acharatlal Varaiya (2023) 152 taxmmann.com 656 (Guj)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Writ petition was dismissed-SLP is disposed following the order in UOI v. Rajeev Bansal [2024] 301 Taxman 238 (SC). [S. 148A(b), 148A(d), Art. 136]

Dinesh Verma v. ITO (2025) 302 Taxman 367 (SC) Editorial: Dinesh Verma v. ITO (2022) 141 taxmann.com 453/ 456 ITR 682 (P& H)(HC)

S. 147: Reassessment-Capital gains-Land used for agricultural purposes-Reassessment notice is justified. [S. 45, 54B, 143(3), 148, Art. 226.]

Yogesh Kumar Saini v. UOI (2025) 302 Taxman 427 (Raj.)(HC)

S.147: Reassessment-After the expiry of four years-Unexplained investment-Borrowed satisfaction-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S. 69, 142(1), 148, Art.226]

Om Synergy Spacelink (P.) Ltd. v. NFAC (2025) 302 Taxman 201 (Guj.)(HC)

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Business expenditure-Discovery appreciation plan (DAP)-Material for reopening assessment had been gathered from assessment record of subsequent year-Reasons recorded stated that the claim was allowed by mistake-Change of opinion-Notice and order disposing the objection is set aside. [S. 37(1),143(3), Art. 226]

Discovery Communications India v. Addl. CIT (2025) 302 Taxman 246 / 473 ITR 627 (Delhi)(HC)

S.147: Reassessment-After the expiry of four years-Disallowance of expenditure-Exempt income-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed by High Court-Delay of 457 days-SLP of Revenue is dismissed on the ground that reasons assigned are neither satisfactory nor sufficient in law to condone the delay of 457 days. [S. 14A, 148, 263, Art. 136]

Dy. CIT v. Unitech Ltd. (2025) 302 Taxman 372 (SC) Editorial : Unitech Ltd v. Dy.CIT (2017) 397 ITR 547 / (2018) 99 taxmann.com 455(Delhi)(HC)

S. 144C : Reference to dispute resolution panel-Pendency of objection-Order is set aside. [Art. 226]

Jackson Square Aviation Ireland Ltd. v. ACIT (2025) 302 Taxman 502 (Delhi)(HC)

S. 144 : Best judgment assessment-Pendency of appeal and revision-Assessment order is stayed till proceedings before Appellate Authority or Revisional Authority were decided. [S. 144B, 148, 246A, 264, Art. 226]

Real Infrastructure Co. v. ITO (2025) 302 Taxman 116 (Bom.)(HC)

S. 143(3): Assessment-Error in heading was result of an inadvertent systemic error-Clarification issued by the Assessing Officer-Writ petition is dismissed. [S. 144C, Art. 226]

BT Global Communications India (P.) Ltd. v. DCIT (2025) 302 Taxman 298 (Delhi)(HC)