Monthly Archives: May 2026

Interim Stay or Invalidity of Third-Party Search Does Not Vitiate Section 148 Proceedings Against Assessee Issue Whether a notice issued under the Second Explanation to Section 148, based on material recovered from a search of a third party, becomes invalid or without jurisdiction if the search itself is subsequently stayed or declared void by a… Read More »

Principal Commissioner Justly Rejects Condonation Request as Return Filed Beyond Prescribed Five-Year Circular Limit Issue Whether the Principal Commissioner was justified in rejecting a condonation of delay application filed beyond the five-year limit prescribed by CBDT Circular No. 9 of 2015. Whether the non-issuance of a notice under Section 148 grants an assessee an inherent… Read More »

Ad-Hoc Net Profit Additions and Unsecured Loan Deletions Sustained as Assessing Officer Failed to Reject Books Issue Whether the Assessing Officer (AO) can legally estimate a higher net profit rate solely based on a decline in profitability without rejecting the assessee’s books of account or identifying specific false expenditures. Whether an addition under Section 68… Read More »