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-The issue involved in SLP was covered in UOI v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238 (SC)-SLP filed by revenue against order of High Court was disposed of-The Assessing Officer will dispose of the objections in terms of law laid down by the apex court in Rajeev Bansal (Supra).The assessee is given liberty to pursue all the rights and remedies in accordance with law.[S. 148, 148A(b)), 148A(d), 149, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 136]

ACIT v. Sanman Trade Impex Ltd. (2025) 303 Taxman 333 (SC) Editorial : Virendra ship Recylers LLP v.ACIT(2025) 170 taxmann.com 588 (Bom)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Time limit for notice-SLP disposed of in terms of Supreme Court judgment in UOI v. Rajeev Bansal (2024) 301 Taxman 238 (SC).[S. 148A(b), 148A(d), 149, Art. 136]

ITO v. Vinal Comtrade (P.) Ltd. (2025) 303 Taxman 106 (SC) Editorial: Vinal Comtrade (P.) Ltd. v. ITO (2024) 169 taxmann.com 679 (Guj.)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Large cash deposits-Inadequate explanation-Reassessment notice is held to be justified-SLP dismissed as withdrawn.[S.68, 148A(b),148A(d), Art. 136].

Dhan Prakash Gupta v. Income-tax Dept. (2025) 303 Taxman 257 (SC) Editorial : Dhan Prakash Gupta v. Income-tax Dept (2025)170 taxmann.com 665 (Delhi)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Interest on borrowed capital-Diversion of fund-Assessing Officer was not disabled from proceeding to examine entire case, including on basis of allegations which formed part of original reasons to believe-High Court dismissed the writ petition-SLP of assessee is dismissed. [S. 36(1)(iii) 147, 148, 148A(b), 148A(d), Art. 136]

Alankar Apartments (P.) Ltd. v. ACIT (2025) 303 Taxman 109/477 ITR 405 (SC) Editorial : PCIT v. Alankar Apartments (P.) Ltd(2024) 169 taxmann.com 682 /(2025) 477 ITR 399 (Delhi)(HC)

S. 148 : Reassessment-Notice-Issued after approval of resolution plan by NCLT for a prior period-Invalid-SLP dismissed. Insolvency and Bankruptcy Code, 2016, S. 31, Art. 136]

Pr. CIT v. Patanjali Foods Ltd. (2025) 303 Taxman 330 / 474 ITR 339 (SC) Editorial: Pr. CIT v. Patanjali Foods Ltd. (2024) 161 taxmann.com 675 / 474 ITR 333 (Bom.)(HC)

S. 147 : Reassessment-Long-term capital gains from equities-Bogus claim-Accommodation entries-Information from Investigation Wing-Loan-No independent satisfaction regarding reasons recorded to re-open assessment-Reassessment notice and order disposing the objection is quashed. [S. 10(38), 45, 132, 148, Art. 226]

Ashishbhai Jashwantbhai Desai HUF v. ITO (2025) 303 Taxman 578 (Guj.)(HC)

S. 147 : Reassessment-Capital gains-Capital gains-Investment in a residential house-Alternate remedy-Writ petition is dismissed. [S.54F 143(3),148, Art.226]

Vijay Vasant Kulkarni v. ACIT (2025) 303 Taxman 519 (Bom)(HC)

S.147: Reassessment-After the expiry of four years-Futures & Options-Loss was accepted in the original assessment-Information received from insight portal-No independent verification-No failure to disclose material facts-Notice and order disposing the objection was quashed and set aside [S. 28(1), 143(3), 148, Art. 226]

Ashvin Dye-Chem Industries v. ITO (2025) 303 Taxman 621 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Futures & options loss-Borrowed satisfaction-No failure to disclose-Notice quashed [S. 71, 148, Art. 226]

Rikin Industries v. ITO (2025) 303 Taxman 393 (Guj)(HC)

S. 147 : Reassessment-Cash credits-Bogus sales-Special Audit report-Reopening based only on NSEL information-Delay of 122 days not been satisfactorily explained-SLP dismissed both for delay and on merits. [S. 68, 143(3), 148, Art. 226]

ACIT v. N.K. Industries Ltd. (2025) 303 Taxman 262 (SC) Editorial : N.K. Industries Ltd v. ACIT (2024) 165 taxmann.com 194 (Guj)(HC)