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
Click here to download the pdf versions of the Digest of case laws

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Merged entity-Cash credits-Non-application of mind-PAN number was deactivated-Reassessment notice and consequential orders are quashed-SLP of revenue is dismissed. [S. 148, 148A(b), 148A(d), Art. 136]

Dy. CIT v. Rasna (P.) Ltd. (2026) 310 Taxman 660 (SC) Editorial : Rasna (P) Ltd v.Dy.CIT (2026) 185 taxmann.com 987 (Guj)(HC)

S. 148: Reassessment-Notice-Merger-Initiated to the Assessing Officer-Assessment and order were issued in the name of a non-existent entity-High Court quashed the notice and assessment-[S. 143(3), 260A, 292B]

CIT, LTU Shell India Markets (P.) Ltd(2025) 174 taxmann.com 349 (Bom)(HC) Editorial : SLP of revenue dismissed, CIT, LTU v. Shell India Markets (P.) Ltd. (2026) 310 Taxman 1 (SC)

S. 148 : Reassessment-Notice-Merger-Waiver of tax liability-Assessment year 2021-22-Assessee-corporate debtor underwent insolvency resolution and a revised assessee underwent insolvency, and a resolution plan approved by NCLT extinguished all prior tax liabilities-Assessing Officer issued notices under sections 148 and 142 for a period prior to approval-No belated claims could be raised after approval of resolution plan-High Court quashed the notice and consequential orders. [S. 147, the Insolvency and Bankruptcy Code, 2016, S. 31, Art.226]

Ornate Spaces (P.) Ltd v. Dy.CIT (2026) 185 taxmann.com 422 (Bom) HC) Editorial : SLP of revenue dismissed, Dy. CIT v. Ornate Spaces (P.) Ltd. (2026) 310 Taxman 405 (SC)

S. 148: Reassessment-Notice-Merger-High Court quashed the notice and consequential orders; SLP of revenue quashed. [S. 147, the Insolvency and Bankruptcy Code, 2016, S. 31, Art. 136]

Dy. CIT v. Ornate Spaces (P.) Ltd. (2026) 310 Taxman 405 (SC) Editorial: Ornate Spaces (P.) Ltd v.Dy.CIT (2026) 185 taxmann.com 422 (Bom)(HC)

S. 148: Reassessment-Notice-Failure to dispose of objection-Reassessment notice and consequential orders are bad in law-SLP of revenue dismissed. [S. 147, Art. 136]

Dy. CIT v. Hewlett Packard Financial Services (India) (P.) Ltd. (2026) 310 Taxman 2 (SC) Editorial : Dy. CIT v. Hewlett Packard Financial Services (India) (P.) Ltd(2026) 183 taxmann.com 596 (Karn)(HC)

S. 148: Reassessment-Notice-Merger-Initiated to the Assessing Officer-Assessment and order were issued in the name of a non-existent entity-High Court quashed the notice and assessment-SLP of revenue was dismissed. [S. 143(3), 292B, Art. 136]

CIT, LTU v. Shell India Markets (P.) Ltd. (2026) 310 Taxman 1 (SC) Editorial: CIT, LTU Shell India Markets (P.) Ltd(2025) 174 taxmann.com 349 (Bom)(HC)

S. 147: Reassessment-Co-owner-Reopening of assessment in case of mother of assessee, who was co-owner of land in question, had already been quashed and set aside; jurisdictional notice issued under section 148, reassessment order passed under section 147 and penalty notice issued under section 271DA were quashed and set aside. [S.271DA, 148, Art. 226]

Shardaben Hashmukhbhai Patel v. ITO (2026) 310 Taxman 706 (Guj)(HC)

S. 147: Reassessment-Industrial undertakings-Infrastructure development-Audit objection-Order of the Tribunal quashing the reassessment was affirmed. [S.80IA, 148, 260A]

PCIT v. NTPC Ltd. (2026) 310 Taxman 54 (Delhi)(HC)

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)