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Supreme Court

Supreme Court Allows Revenue Appeals in Section 153A Search Assessment Dispute — Assessing Officer Can Assess Total Income Including Non-Incriminating Material. The Court held that under Section 153A of the Income Tax Act, 1961, the Assessing Officer is competent to assess total income considering all material on record, not limited to incriminating material found during search.

24 Apr 2023

This batch of appeals involves a common question of law regarding the scope of assessment under Section 153A of the Income Tax Act, 1961. The Revenue ...

High Court

High Court Quashes Income Tax Reopening Notices in Search-Based Assessment Cases Due to Mandatory Application of Section 153C. Assessing Officer Cannot Invoke General Reassessment Provisions Under Sections 147/148 When Material Originates from Search Under Section 132/132A, as Special Provisions Under Section 153C Override and Require Exclusive Procedural Compliance.

7 Jan 2026

The judgment concerned a group of petitions challenging notices issued under Section 148 of the Income-tax Act, 1961, reopening assessments under Sect...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Search Action Under Section 132 Cannot Be Basis for Reopening Beyond Four Years Without New Tangible Evidence.

23 Feb 2026

The petitioner, Mahesh Dharamshi Prajapati, an individual and major partner of PSY Group engaged in real estate business, filed his return of income f...

High Court

Gujarat High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Assessment Year 2015-16 Due to Lack of Live Link and Absence of Allegation of Failure to Disclose Material Facts. Notice Issued Beyond Four Years Without Proper Satisfaction That Income Escaped Assessment Due to Assessee's Failure to Disclose Material Facts.

26 Feb 2026

The petitioner, Jaini Tradelink Pvt. Ltd., a company engaged in wholesale and retail trade and acting as a commission agent, filed its return of incom...

Supreme Court

Supreme Court Upholds Revenue in Income Tax Reassessment Case on Limitation and Computation Grounds. Reassessment under Sections 147 and 148 of Income Tax Act, 1961 Held Valid as Assessee Failed to Disclose Material Facts, and Notice Served on Partnership Firm Was Proper Despite Section 282(2) Argument.

23 Jan 2024

The dispute arose from reassessment proceedings under the Income Tax Act, 1961, involving a partnership firm engaged in publishing newspapers and peri...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Non-Application of Mind. Notice Issued Based on Search Materials Without Independent Satisfaction or Opportunity of Hearing Held Invalid.

9 Mar 2026

The petitioner, Dilipbhai Prabhudas Patel, an individual and part of the PSY Group engaged in real estate business, filed his return of income for Ass...

High Court

Gujarat High Court Quashes Reassessment Notice in Income Tax Case Due to Non-Application of Mind by AO. Section 148 Notice for AY 2014-15 Set Aside as Reasons Recorded Were Mechanical and Lacked Independent Satisfaction.

20 Mar 2026

The petitioner, Sanvira Holdings, a partnership firm part of the PSY Group engaged in real estate business, filed its return of income for Assessment ...

High Court

Gujarat High Court Quashes Reassessment Notice for AY 2014-15 Due to Limitation Under Section 149(1)(b) of Income Tax Act, 1961. Notice issued beyond six-year period from end of assessment year held invalid as escaped income did not involve assets of value exceeding Rs. 50 lakhs.

20 Mar 2026

The petitioner, a major partner of PSY Group engaged in real estate business, challenged a notice dated 27.03.2025 issued under Section 148 of the Inc...

High Court

Gujarat High Court Quashes Reassessment Notice and Assessment Order in Income Tax Case Due to Lack of Incriminating Material and Non-Application of Mind. Section 153C Notice for Assessment Year 2010-11 Set Aside as No Satisfaction Recorded Regarding Incriminating Documents Found During Search of Third Parties.

30 Mar 2026

The petitioner, Pankajkumar Kanaiyalal Soni, an individual, challenged a notice dated 09.07.2021 issued under Section 153C of the Income Tax Act, 1961...

High Court

Gujarat High Court Allows Petition Challenging Reopening Notice Under Section 148 for AY 2012-13 as Time-Barred. Notice Issued Beyond Six-Year Limit Under Section 149 After Search Under Section 132 on 08.09.2021.

23 Feb 2026

The petitioner, Manojbhai Bhupatbhai Vadodaria, filed a writ petition challenging a notice under Section 148 of the Income Tax Act, 1961 for Assessmen...

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