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. 148 : Reassessment-Notice-Cash credits-Notice must be issued by the Faceless Assessing Officer (FAO) and not by the Jurisdictional Assessing Officer (JAO)-Notice issued by JAO is a fatal defect and quashed.[S. 147, Art. 226]

Caishen Enterprise LLP v. ACIT(2025) 306 Taxman 138 (Bom)(HC)

S. 147 : Reassessment-With in four years-Change of opinion-Depreciation-Survey-Examined during the original assessment proceedings-Reassessment not valid-Omission to pass a speaking order on receipt of objections cannot be considered as fatal.[S. 133A,143(3), 148, Art. 226]

SI Property (Kerala) (P.) Ltd. v. CIT (2025) 306 Taxman 44 (Ker.)(HC)

S. 147 : Reassessment-With in four years-Deemed Dividend-Trade Advances-Credit Balances-Common Shareholding-Reassessment Invalid. [S.2(22)(e), 148, Art. 226]

Relitrade Stock Broking (P.) Ltd. v. ITO (2025) 306 Taxman 133 (Guj.)(HC)

S. 147 : Reassessment-With in four years-Interest on borrowed capital-Change of opinion-Full disclosure during original assessment-Reopening held invalid.[S.36(1)(iii), 147, Art. 226]

Sundararajan (P.) v. DCIT (2025) 306 Taxman 115 (Mad.)(HC)

S. 147: Reassessment-After the expiry of four years-Alleged bogus purchases-Unexplained expenditure-Full disclosure-Reason to suspect-Order of Tribunal quashing the reassessment order was affirmed. [S.69C, 148, 260A]

PCIT v. Purple Suppliers (P.) Ltd. (2025) 306 Taxman 145 (Cal.)(HC)

S. 147 : Reassessment-After the expiry of four years-Non-compete Fee-Revenue expenditure-Change of opinion-Full disclosure of facts-Reassessment notice and order disposing the objection was quashed.[S. 37(1), 148, Art. 226]

Revathi Equipment Ltd. v. ACIT (2025) 306 Taxman 72/2026) 484 ITR 768 (Mad.)(HC)

S.147: Reassessment-After the expiry of four years-Educational Society-Accumulation of income-Reassessment notice and order disposing the objection was quashed and set aside. [S. 11 (2), 14 Art. 226]

Symbiosis Open Education Society v. ACIT(2025) 306 Taxman 62 (Bom.)(HC)

S. 147: Reassessment-Unexplained money-Unaccounted sales-Information from Partner’s Complaint-Opportunity of Hearing-No Reliance Solely on Third-Party-Writ not maintainable-SLP of assessee dismissed. [S.69A, 148, Art. 136]

Shree Shakambhari Udyog Partnership Firm v. CIT (2025) 306 Taxman 339 (SC) Editorial: Shree Shakambhari Udyog Partnership Firm v. CIT (2025) 173 taxmann.com 955 (Pat) (HC)

S.147 : Reassessment-Cash credits-Information from GST data-Non-furnishing of sales and purchase register-Assessee furnished GSTR-I and complete audited books-Reopening unjustified-Delay of 233 days-SLP of revenue was dismissed on account of delay as well as on merits. [S. 68,148, Art. 136]

ITO v. Parmukh Exports [2025] 306 Taxman 356 (SC) Editorial : Parmukh Exports v. ITO (2025) 177 taxmann.com 227 (Guj)(HC)

S. 147 : Reassessment-Alternative remedy-Filing appeal-Writ petition was dismissed-SLP of assessee dismissed.[S. 144B,148, Art. 136]

Manju Arora v. ITO [2025] 306 Taxman 91 (SC) Editorial :Manju Arora v. ITO (2025) 176 taxmann.com 343 (Delhi)(HC)