Landmark Rulings

The Ahmedabad ITAT quashed reassessment proceedings against Vishnu Pouch Packaging, holding that a Section 148 notice issued on 27 July 2022 was beyond the surviving limitation period under TOLA after applying the Supreme Court’s Rajeev Bansal principle.

Karnataka High Court reads down the Finance Act 2010 Explanation to Section 9(2) as prospective, holding that offshore technical services utilized in India but rendered abroad are not taxable under Section 9(1)(vii). The twin-condition test from Ishikawajima-Harima survives.

ITAT Ahmedabad, in Nitiben Nayaneshkumar Trivedi vs. ITO, remands the matter back to the Assessing Officer for fresh adjudication, granting the assessee a final chance to furnish sources for unexplained money under Section 69A.

The Jharkhand High Court ruled that interest under Section 132B(4) of the Income Tax Act is payable on seized cash even when no assessment is completed, directing payment at 6% per annum from 120 days after search till refund, and 12% for further delay.

The Calcutta High Court quashed the Section 143(3) assessment order against Pricewaterhouse Coopers Pvt Ltd for AY 2024-25, holding that passing the order on the same day as the assessee’s reply constitutes gross violation of natural justice. The Court reaffirmed that effective opportunity of hearing is mandatory, even in faceless assessment regimes.

Calcutta HC Quashes Reassessment Notice for Ignoring Assessee’s Reply Court: Calcutta High Court Case Name: Ojaswini Retailers Private Limited & Anr. vs. Union of India & Ors. Date of Judgment: 11th June 2026 Key Sections:

ITAT Quashes Final Order for Non-Compliance with DRP Directions Court: Income Tax Appellate Tribunal, Bangalore ‘B’ Bench Case Name: Marlabs Innovations Private Limited vs. Deputy Commissioner of Income Tax, Circle – 4(1)(1), Bangalore Date of

Masuda Begum Case: Burden of Proof Under Section 9 of Foreigners Act Court: Gauhati High Court Case Name: Masuda Begum @ Mashuda Begum vs. Union of India and 5 Others Date of Judgment: 26.02.2026 (Judgment