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Section 153C Proceedings Invalid Without Year-Specific Incriminating Material; Notices for AYs 2015–16 to 2020–21 Quashed – Neeraj Bharadwaj vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Neeraj Bharadwaj, challenged multiple notices dated 24.06.2024 issued under
Section 153C of the Income-tax Act, 1961 for Assessment Years 2015–16 to
2020–21. The notices were issu...
Search-Based Reassessment for AY 2014–15 Barred by Limitation; Ten-Year Block under Section 153A Computed from AY of Search – Notice under Section 148 Quashed – N S Associates Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner, N
S Associates Private Limited, filed a writ petition challenging the notice
dated 04.02.2025 issued under Section 148 of the Income-tax Act, 1961 for
Assessment Year 2014–15 and th...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year: Search-Based Reopening Quashed – Mirza Qamarul Hasan Beg vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Mirza Qamarul Hasan Beg, filed a writ petition challenging the notice dated
22.03.2025 issued under Section 148 of the Income-tax Act, 1961 for Assessment
Year 2014–15 and the proce...
Unsecured Loan Treated as Unexplained Credit Where Identity and Creditworthiness of Lender Not Established; No Substantial Question of Law – Meenakshi Gupta vs. ITO (Delhi High Court)
Facts of the
CaseThe assessee,
Meenakshi Gupta, filed an appeal under Section 260A of the Income-tax Act, 1961
challenging the order dated 06.01.2025 passed by the Income Tax Appellate
Tribunal for Assessment Year 20...
Reassessment for AY 2014–15 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO to Decide Limitation Afresh – Manish Gupta vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Manish Gupta, filed a writ petition challenging the order dated 20.07.2022
passed under Section 148A(d) of the Income-tax Act, 1961 and the consequential
notice dated 20.07.2022 issue...
Reassessment for AY 2013–14 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO for Fresh Decision on Limitation – Dhurav Real Estate Developers Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Dhurav Real Estate Developers Private Limited, filed a writ petition
challenging the order dated 28.07.2022 passed under Section 148A(d) of the
Income-tax Act, 1961 and the consequent...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year: Search-Based Reopening Quashed – Davander Rawat vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Davander Rawat, filed a writ petition challenging the notice dated 26.03.2025
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2014–15 and all proceedings in...
Compensation and Interest Received under Arbitral Award for Offshore Supplies Constitute Business Income; Not Taxable in Absence of PE under India–Japan DTAA – CIT (IT)-1 vs. Fujitsu Limited (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the order
dated 14.11.2024 passed by the Income Tax Appellate Tribunal in ITA No.
2607/Del/2022 for Assessment Y...
Reassessment Notices for AY 2015–16 Issued After 01.04.2021 Are Time-Barred; TOLA Inapplicable – Following Rajeev Bansal – Banyan Capital Advisors LLP vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Banyan Capital Advisors LLP, filed a writ petition challenging the original
notice dated 30.06.2021 issued under Section 148, the subsequent order dated
30.06.2022 passed under Sectio...
Reassessment Proceedings Quashed for Review of Section 148A(d) Order and Limitation Breach: AO Has No Power of Review – Baba Global Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Baba Global Ltd., filed a writ petition challenging the notice dated 31.03.2023
issued under Section 148A(b) of the Income-tax Act, 1961, a corrigendum dated
28.04.2023, the order dat...