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. 271AAA : Penalty- Search initiated on or after 1st June, 2007- Failure to substantiate the manner of undisclosed income was earned- Order of High Court is affirmed- SLP of assessee is dismissed.[S. 132(4),271AA(2), Art. 136]

Amul Gabrani v. PCIT (2025)472 ITR 13/302 Taxman 410 (SC) Editorial : PCIT v. Amul Gabrani (2024) 169 taxmann.com 503 /472 ITR 3 (Delhi)(HC)

S. 263 : Commissioner- Revision of orders prejudicial to revenue-Order of High Court on identical issue for different assessment year- Matter remanded to commissioner. [Art. 226]

Sri Sai Swadhin Commercial Pvt. Ltd. v. PCIT (2025)472 ITR 589 (AP)(HC)

S.234E : Fee-Default in furnishing the statements- Deduction of tax at source-Submission of statement- Amendment with effect from 1-6-2015- Amendment not retrospective-Not applicable prior to 1-6-2015.[S.200A(1)(c), Art. 226]

True Blue Voice India Pvt. Ltd. v. Chief CIT (TDS) (2025)472 ITR 480 / 158 taxmann.com 67 (Mad)(HC)

S. 158BC : Block assessment- Undisclosed income- On money- Purchase of agricultural property- No incriminating material- Purchaser declaring capital gains-Seized documents without signature and statement of original owners- Addition is deleted. [S. 132, 260A]

Dr. Syed Anwar v. Dy. CIT [2023] 146 taxmann.com 247/ (2025)472 ITR 551 (Karn)(HC)

S. 153C : Assessment- Income of any other person- Search-No valid transfer of case-Assessment by Assessing Officer in Andhra Pradesh is not valid- Alternative remedy not an absolute bar for issue of writ- Question regarding jurisdiction to exercise power can be raised at any stage of proceedings.[S. 127, Art. 226]

Vijay Nathulal Sharma v. Dy. CIT [2023] 146 taxmann.com 15 / (2025)472 ITR 535 (AP)(HC)

S. 148A : Reassessment- Conducting inquiry, providing opportunity before issue of notice-Seizure of cash by police-Proceedings under section 132A- Notice is valid though issued non compliance of procedure.[S.132A, 147, 148, Criminal Procedure Code, 1973, S 451]

Muhammed C. K. v. ACIT (NO. 1) (2025)472 ITR 161 (Ker)(HC) Editorial : Decision of single judge is affirmed, Muhammed C. K. v. ACIT (NO. 3) (2025)472 ITR 166 (Ker)(HC)

S. 148A : Reassessment- Conducting inquiry, providing opportunity before issue of notice- Seizure of cash by police —Proceedings under section 132A- Notice is valid though issued non compliance of procedure- Order of single judge is affirmed. [S.132A, 147, 148, Criminal Procedure Code, 1973, S 451]

Muhammed C.K. v. ACIT (NO. 3) (2025)472 ITR 166 / 172 taxmann.com 198 (Ker)(HC) Editorial : Muhammed C. K. v.ACIT (NO. 1) (2025)472 ITR 161 (Ker)(HC)

S. 148A : Reassessment- Conducting inquiry, providing opportunity before issue of notice- Unable to file reply to initial notice within time granted owing to technical glitch on portal —Reply was filed prior passing of the order- Natural justice- Order is not valid. [S.148A(b), 148A(d), Art. 226]

Kiran Milapchand Jain (Smt.) v. Review Unit, Income-Tax Department (2025)472 ITR 644 (Karn)(HC)

S. 148 : Reassessment-Notice- Death of assessee-Notice in name of deceased assessee- Notice is not valid.[S. 147, 159, Art. 226]

Sujata Devi v. ITO (2025)472 ITR 463 (Jharkhand)(HC)

S. 147 : Reassessment-Natural justice- Opportunity of hearing- Order passed without giving an adequate opportunity of hearing is not valid. [S. 148, Art. 226]

Tadimalla Gowthami v. ITO (2025)472 ITR 150 / 171 taxmann.com 310 (Mad)(HC)