Monthly Archives: May 2026

An inherited farm’s agricultural income covers modest cash deposits, invalidating a factually flawed reassessment notice. Issue Whether a reassessment notice issued under section 148 is legally sustainable when based on incorrect factual figures and a lack of independent application of mind by the Assessing Officer, and whether modest bank cash deposits can be treated as… Read More »

Reassessment for AY 2015-16 is quashed due to limitation bars and incorrect investment year. Issue Whether the reassessment proceedings initiated via a section 148 notice dated April 12, 2022, for the assessment year 2015-16 were barred by limitation and lacked proper application of mind by the Assessing Officer. Whether an addition for an unexplained investment… Read More »

Tax liabilities for period prior to CIRP stand extinguished upon approval of resolution plan. Issue Whether the Assessing Officer has the jurisdiction to pass a reassessment order or issue a demand notice under section 156 for a pre-CIRP period after the NCLT has already approved a corporate resolution plan under Section 31 of the Insolvency… Read More »

Assessing Officer’s failure to follow mandatory Dispute Resolution Panel directions invalidates the final assessment. Issue Whether a final assessment order making tax additions under section 40(a)(i) can be legally sustained if the Assessing Officer deliberately fails to comply with a conditional and mandatory direction issued by the Dispute Resolution Panel (DRP) under section 144C(10). Facts… Read More »

Reassessment is quashed as notice issued beyond three years lacked mandatory approval from higher authority. Issue Whether a reassessment notice issued under section 148 beyond three years from the end of the relevant assessment year is legally valid if it was approved by the Principal Commissioner of Income Tax (PCIT) instead of the statutorily mandated… Read More »

Uncorroborated search additions, jewelry investments, and related tax claims are remanded for fresh factual adjudication. Issue Whether additions for alleged “on-money” based on a loose paper, unexplained jewelry, capital gains exemptions, and cash credits can be finalized without a comprehensive examination of factual evidence and statements. Whether section 153C search assessment proceedings against a third… Read More »

IPL franchisee’s franchise fees, celebrity hospitality, website charges, and paid provisions are deductible revenue expenditures. Issue Whether an IPL franchisee company is entitled to claim revenue deductions for its annual franchise fees, celebrity-related hospitality and travel costs, website expenses, club fees, and year-end salary and bonus provisions. Facts Franchise Fees: The assessee, an IPL franchise… Read More »