Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred

By | July 25, 2026
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Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred Issue Computation of Ten-Year Block Period under Section 153A/153C: Whether the assessment year relevant to the previous year in which the search was conducted is… Read More »

Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year

By | July 25, 2026
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Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year Issue Validity of Reassessment Order Based on Mismatched Show Cause Notice: Whether a reassessment order passed under Section 147 read with Sections 144 and 144B can be… Read More »

Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required

By | July 25, 2026
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Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required Issue Condonation of Delay under Section 119(2)(b) for Section 80P Deduction: Whether a co-operative society’s application seeking condonation of delay under Section 119(2)(b)… Read More »

Section 263 Revision Is Invalid Where Restricting Bogus Purchase Addition To 12.5% Is Plausible

By | July 25, 2026
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Section 263 Revision Is Invalid Where Restricting Bogus Purchase Addition To 12.5% Is Plausible Issue Validity of Section 263 Revision on Plausible Disallowance Views: Whether the Principal Commissioner of Income Tax (PCIT) can invoke revision powers under Section 263 to demand a 100% addition under Section 69C (taxed under Section 115BBE) when the Assessing Officer… Read More »

Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings

By | July 25, 2026
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Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings Issue Validity of Section 153C Assessment Proceedings Based on a Consolidated Satisfaction Note: Whether the initiation of proceedings and subsequent additions made under Section 69A (read with Section 153C) are legally valid when the Assessing Officer records a single, common satisfaction note covering multiple… Read More »

Reassessment Valid as Wealth Tax Disclosures Do Not Exempt Taxpayer From Proving Income Sources

By | July 25, 2026
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Reassessment Valid as Wealth Tax Disclosures Do Not Exempt Taxpayer From Proving Income Sources Issue Validity of Reassessment under Section 147 for Unexplained Investments: Whether a notice issued under Section 148 for unexplained investment in property (including a substantial cash component) is valid when the original return was processed only under Section 143(1), even if… Read More »

Estimated Addition On Suppressed Professional Receipts Based On Third-Party Statements Without Account Rejection Is Unsustainable

By | July 25, 2026
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Estimated Addition On Suppressed Professional Receipts Based On Third-Party Statements Without Account Rejection Is Unsustainable Issue Validity of Reassessment Addition Based on Estimation: Whether an addition made on account of alleged suppression of professional receipts—calculated purely on estimated hospital consultation charges and manager statements without rejecting the assessee’s books of account or bringing independent corroborative… Read More »

PCIT Can Revise Faceless Assessment Orders Where AO Fails To Enquire Into Unverified Claims

By | July 25, 2026
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PCIT Can Revise Faceless Assessment Orders Where AO Fails To Enquire Into Unverified Claims Issue Jurisdiction under Section 263 over Faceless Assessment Orders: Whether a Principal Commissioner of Income Tax (PCIT) has the legal authority under Section 263 to revise an assessment order passed under Section 144B by the National Faceless Assessment Centre (NaFAC). Validity… Read More »

Interest Paid On Related-Party Loans Cannot Be Disallowed By Netting Trade Advances Or Adding Notional Interest

By | July 25, 2026
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Interest Paid On Related-Party Loans Cannot Be Disallowed By Netting Trade Advances Or Adding Notional Interest Issue Netting of Loan and Current Accounts under Section 40A(2): Whether the Assessing Officer (AO) can disallow interest paid on an unsecured loan from a related party by netting it against a trade advance/current account, without proving that the… Read More »

Reassessment Notice Premised On Factually Incorrect Scrip Name Is Invalid And Liable To Be Quashed

By | July 25, 2026
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Reassessment Notice Premised On Factually Incorrect Scrip Name Is Invalid And Liable To Be Quashed Reassessment Notice Premised On Factually Incorrect Scrip Name Is Invalid And Liable To Be Quashed Issue Validity of Reassessment Premised on Factually Incorrect Information: Whether a reopening notice issued under Section 148 read with Section 147 is legally sustainable when… Read More »