Tag Archives: HIGH COURT OF GUJARAT

Reassessment Cannot Be Based on Conjectures, Surmises, or Third-Party Evidence Lacking a Direct Link to the Assessee

By | June 18, 2026
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Reassessment Cannot Be Based on Conjectures, Surmises, or Third-Party Evidence Lacking a Direct Link to the Assessee Issue Whether a reassessment notice under Section 148 and its preparatory orders under Section 148A can be legally sustained when the alleged escapement of income is based entirely on third-party digital data without establishing any direct, corroborative link… Read More »

Passing Assessment Order Without Providing Reasonable Opportunity Violates Principles Of Natural Justice

By | June 16, 2026
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Passing Assessment Order Without Providing Reasonable Opportunity Violates Principles Of Natural Justice Passing Assessment Order Without Providing Reasonable Opportunity Violates Principles Of Natural Justice Issue Whether a best judgment assessment order passed under Section 144 read with Section 144B is legally sustainable when the Revenue provides inadequate response windows, ignores an adjournment request, and gives… Read More »

DGCEI is a Law Enforcement Agency, Exempting Departmental Appeals From CBDT Monetary Limits

By | June 16, 2026
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DGCEI is a Law Enforcement Agency, Exempting Departmental Appeals From CBDT Monetary Limits Issue Whether the Directorate General of Central Excise Intelligence (DGCEI) qualifies as a “law enforcement agency” under paragraph 10(e) of the CBDT Circular dated 11.07.2018 (read with Circular dated 20.08.2018), thereby exempting the Revenue’s appeal from the standard Rs. 50 lakhs low… Read More »

Reassessment Notices Issued Beyond the Recomputed Supreme Court Timeline and TOLA Extensions Are Time-Barred and Invalid

By | June 15, 2026
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Reassessment Notices Issued Beyond the Recomputed Supreme Court Timeline and TOLA Extensions Are Time-Barred and Invalid Issue Whether the reassessment order passed under Section 148A(d) and the subsequent notice issued under Section 148 on July 29, 2022, for Assessment Year 2014-15, are legally sustainable or invalid as being barred by the law of limitation. Facts… Read More »

Reassessment Notice Issued Beyond The Supreme Court Mandated Calculation Period Post-Ashish Agarwal And Rajeev Bansal Ruling Is Invalid As Time-Barred

By | June 13, 2026
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Reassessment Notice Issued Beyond The Supreme Court Mandated Calculation Period Post-Ashish Agarwal And Rajeev Bansal Ruling Is Invalid As Time-Barred Reassessment Notice Issued Beyond The Supreme Court Mandated Calculation Period Post-Ashish Agarwal And Rajeev Bansal Ruling Is Invalid As Time-Barred Issue Whether the reassessment order under Section 148A(d) and the subsequent notice under Section 148,… Read More »