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. 153A: Assessment-Search-Alleged unaccounted addition-Rejection of books of account-Order of the High Court deleting the addition is affirmed-SLP of revenue dismissed. [S.143(3), Art. 136]

ACIT (Central) v. Mahamaya Steel Industries Ltd. (2026) 310 Taxman 487 (SC) Editorial: ACIT (Central) v. Mahamaya Steel Industries Ltd. (2026) 185 taxmann.com 254 (Chhattisgarh) (HC)

S. 153 : Assessment-Reassessment-Limitation-Refund-Even assuming that, prior to amendment, no period of limitation was prescribed, any order now sought to be passed pursuant to directions of the Tribunal dated 03.04.2017 would be unreasonably delayed and barred by limitation. Refund of taxes with applicable interest as directed could not be faulted. [S. 92CA, 237, Art. 226]

Dy. CIT v. Blue Yonder India (P.) Ltd. (2026) 310 Taxman 10 (Karn)(HC) Editorial: Order of single judge, Blue Yonder India (P.) Ltd v. UOI (Karn)(HC) (WP No. 14156 /2025 (T-IT) dt. 11-9-2025)

S. 153: Assessment-Reassessment-Limitation-Order giving effect to the order of the Tribunal-Assessing Officer failed to give effect to the Tribunal’s directions for ten years-Time granted by the Single Judge for refund was to be extended by another eight weeks.[S,143(3), 254(1), Art. 226]

Dy. CIT v. Scicom Contact Centre Service (P.) Ltd. (2026) 310 Taxman 305 (Karn)(HC) Editorial : Oder of single judge, Scicom Contact Centre Service (P.) Ltd v.UOI (WP No. 4474/2024 dt. 21-8 2025 (Karn)(HC)

S. 153: Assessment-Reassessment-Limitation-High Court’s order merely laid down timelines for furnishing reasons and disposing of objections; it did not constitute a ‘finding or direction’ under section 153(6)(i)-Applying section 153(2), first proviso, read with the first proviso to Explanation 1 to section 153, reassessment was barred by limitation.[S.147, 148, 153(6)(i), Art. 226]

S.V.S. Securities Ltd. v. ACIT (2026) 310 Taxman 627 (Bom)(HC)

S. 149 : Reassessment-Time limit for notice-Sanction-Non-resident-Notice under section 148 was issued within three years; sanction under section 151 by PCIT was valid-Decision is pending consideration before Supreme Court, Jurisdictional Assessing Officer was competent to issue notices under sections 148A/148-[S. 10(4)(ii), 10(14), 10(15)(fa), 148, 148A(b), 148A(d), 151, 151A, 26AS, Art. 226,]

Abhinav Jain v. ITO (2026) 310 Taxman 499 / 488 ITR 255 (Delhi)(HC)

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, all notices issued on or after 1-4-2021 under sections 148 and 148A were liable to be dropped as they did not fall within the period prescribed under TOLA.[S. 147, 148, 148A(b), 148A(d), TOLA, Art. 226]

Mohmedmunaf Noormohmed Cambaywala v. ITO (2026) 310 Taxman 703 (Guj)(HC)

S. 149: Reassessment-Time limit for notice-Form of an asset had escaped assessment-All notices issued on or after 1-4-2021 would have to be dropped as they would not fall within the period prescribed under TOLA-Notice under section 148 and all consequential orders/notices, including recovery notices thereof, were quashed and set aside.[S. 148, 148A(b), 148A(d), Art.226]

Mitra Biswas v. ITO (2026) 310 Taxman 44 (Bom)(HC)

S. 149 : Reassessment-Time limit for notice-First proviso to section 149(1) Acts as a restriction on retrospective application of extended ten-year limitation period-Reassessment notice under section 148 was issued in 2024 for assessment year 2013-14, but under erstwhile provisions (as extended by TOLA) time limit for issuance of such notice had already expired on 30-06-2021, by virtue of first proviso to section 149(1), revenue was barred from issuing notice under section 148 under new regime, notwithstanding ten-year period provided in section 149(1)(b) after its amendment by Finance Act, 2021.[S. 148,149(1)(b), TOLA, Art. 226]

Pratibha Syntex Ltd. v. Dy. CIT (2026) 310 Taxman 600 (Bom)(HC)

S. 149 : Reassessment-Time limit for notice-Six years for relevant assessment year 2016-17, expired on 31-3-2022-SLP of revenue dismissed on account of delay of 411 days and also on merits. [S. 148, Art. 136]

ACIT v. Wave Silver Tower (P.) Ltd. (2026) 310 Taxman 331 (SC) Editorial: Wave Silver Tower (P.) Ltd v. ACIT(2025) 171 Taxmann.com 270 (Delhi)(HC)

S. 149: Reassessment-Time limit for notice-Search-Notice was issued beyond the period of six years from the end of the relevant assessment year; said notice was barred by limitation in terms of the first proviso to section 149(1)-SLP dismissed. [S. 132, 148, 148A(b), 148A(d), Art. 136]

Dy. CIT v. E Homes Infrastructure (P.) Ltd. (2026) 310 Taxman 573 (SC) Editorial: E Homes Infrastructure (P.) Ltd v. Dy.CIT (2026) 185 taxmann.com 299 (Delhi)(HC)