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Second Reassessment on Same Issue Invalid Once Prior Section 147 Order Attains Finality | HC

second reassessment section 147

Case Details: Sanjay Kumar Bijay Kumar vs. Principal Commissioner of Income-tax-I - [2026] 184 taxmann.com 475 (Orissa)

Judiciary and Counsel Details

  • Harish Tandon, CJ. & Murahari Sri Raman, J.
  • Pranaya Kishore HarichandanPragyant Harichandan, Advs. for the Petitioner.
  • Subash Chandra Mohanty, Sr. Standing Counsel for the Respondent.

Facts of the Case

The petitioner, a partnership firm, has been carrying on its business dealing in cattle feed and building material on a wholesale and retail basis since 1985-86. It has been furnishing returns under the provisions of the Income Tax Act, 1961, disclosing PAN-2, since Assessment Year 2003-04, but it has never utilised PAN-1 in connection with its business activities. However, due to inadvertence, it disclosed PAN-1 in certain banking transactions with Canara Bank; nonetheless, it requested the Bank to make corrections in its records, listing PAN-2.

On collecting information regarding deposits made with the said Bank, the Deputy Commissioner of Income Tax (DCIT) issued a notice under Section 148 for the assessment of escaped income under Section 147 in respect of PAN-1. Further intimation was also issued in this regard.

The matter reached the Orissa High Court.

High Court Held

The High Court held that the DCIT, while passing an order under Section 148A(3), recorded that the assessee had been filing its returns using PAN AATFS3658P from the Assessment Year 2007-08 onwards. However, the assessee used PAN ABAFS4271L for the bank accounts maintained by it with Canara Bank during the Financial Year 2018-19. It was pertinent to mention that, for a similar ground, the ITO passed an Order under Section 147 read with Section 144, computing the total income of the assessee as nil.

Hence, the reason assigned by the DCIT for initiating the proceeding for assessment was found to be self-contradictory. The DCIT cannot sit over the view expressed on the facts in earlier assessment proceedings on the same subject matter, adjudicated by another quasi-judicial authority. The ITO’s factual narration clearly stated that the assessee had been filing returns using PAN AATFS3658P, but not PAN ABAFS4271L. Thus, the DCIT, while attempting to protect the revenue’s interest, should not be allowed to proceed with the assessment again under Section 147 of the IT Act.

List of Cases Referred to

  • CIT v. Chhabil Dass Agarwal [2013] 36 taxmann.com 36 (SC)/[2013] 217 Taxman 143 (SC)/[2013] 357 ITR 357 (SC) (para 5.1)
  • Godrej Sara Lee Ltd. v. Excise and Taxation Officer-cum Assessing Authority (2023) 3 SCR 871 (para 5.1)
  • Muljibhai Patel v. Nandlal Khodidas Barot AIR 1974 SC 2105 (para 5.2)
  • State of Tripura v. Manoranjan Chakraborty (2001) 10 SCC 740 (para 5.3)
  • VFPL ASIPL JV Company v. Union of India 2020 (III) ILR-CUT 388 (para 5.4)
  • CIT v. Sanjay Kumar Garg [2015] 64 taxmann.com 334 (Delhi) (para 6.14)
  • Kamdhenu Enterprises Ltd. v. ITO [2023] 146 taxmann.com 417 (Delhi) (para 6.15)
  • Kunjan Nair Sivaraman Nair v. Narayan Nair (2004) 3 SCC 277 (para 6.7)
  • CCE, Nagpur v. Shree Baidyanath Ayurved Bhawan Ltd. 2009 taxmann.com 1041 (SC)/[2009] 237 ELT 225 (SC) (para 6.8)
  • Neelima Srivastava v. State of Uttar Pradesh [2022] 8 taxmann.com 1547 (SC) (para 7.2)
  • Experion Developers Pvt. Ltd. v. Himanshu Dewan and Sonali Dewan (2023) 12 SCR 1118 (para 8.1).

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No Reliefs in Going Concern Sale on ‘As Is Where Is’ Basis | NCLT

IBC going concern

Case Details: Arrhum Tradelink (P.) Ltd. vs. Manoj Khattar - [2026] 184 taxmann.com 415 (NCLT-Ahd.)

Judiciary and Counsel Details

  • Mrs Chitra Hankare, Judicial Member & Dr Velamur G Venkata Chalapathy, Technical Member
  • Aadit Sanjanwala, Adv. for the Applicant.
  • Nipun SinghviMayur JugtawatRahul BhavsarNikunt RavalRamchandra MadanIshan AgrawalTirth Nayak, Advs. & Amar N. Bhatt, Senior Adv. for the Respondent.

Facts of the Case

In the instant case, the CIRP was initiated against the corporate debtor and, as no resolution plan was approved, liquidation was ordered. The Liquidator issued a public sale notice for the sale of the corporate debtor as a going concern and conducted an e-auction in which the applicant emerged as the successful bidder.

The applicant filed an application under Section 60(5) of the IBC, seeking relief and concessions, which was dismissed. On appeal, the NCLAT set aside said order, permitting the applicant to file a fresh application for reliefs and concessions.

The applicant filed the present application under Section 60(5)(c) of the IBC seeking broad reliefs, concessions, relaxations and permissions to enable revival and continued operations of the Corporate Debtor as a going concern, asserting acquisition with absolute title free from past liabilities and seeking clean-slate treatment and securities-law related directions, including on delisting/relisting and an effective date.

NCLT Held

The NCLT held that since corporate debtor had been sold on an ‘as is where is’, ‘as is what is’, ‘whatever there is’ and ‘without recourse’ basis and it seemed that no reliefs and concessions sought by applicant were contemplated in terms and conditions of process document, nor consent or opinion sought before proceeding on sale as going concern under Section 32A from this Tribunal, application filed under Section 60(5)(c) by applicant was not maintainable, even if application was filed also under Regulation 32A of IBBI (LP) Regulations read with Rule 11 of NCLT rules. Therefore, the instant application was to be rejected.

List of Cases Reviewed

  • Shantech International (P.) Ltd. v. Devendra Singh CA (AT) (Ins) No. 1520 of 2024 (para 11) followed

List of Cases Referred to

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SCN Without Interest Quantification Invalid Under Section 75(7) | HC

SCN interest quantification

Case Details: Sanjay Construction vs. State of U.P. - [2026] 184 taxmann.com 576 (Allahabad)

Judiciary and Counsel Details

  • Shekhar B. Saraf & Manjive Shukla, JJ.
  • Deepak Kumar PandeyPiyush AgnihotriShailesh Sachan for the Petitioner.

Facts of the Case

The petitioner filed a writ petition challenging the adjudication order passed under whereby tax, interest, and penalty were imposed pursuant to a show cause notice (SCN). It was submitted that although the show cause notice proposed demand of tax, interest, and penalty, it failed to quantify the interest liability despite the relevant period being known at the time of issuance. It was contended that such non-quantification of interest in the SCN was in violation of Section 75(7) of the CGST Act and rendered the entire proceedings invalid. It was further contended that reliance on Section 75(9) to cure such defect was misplaced, as the said provision pertains to non-quantification in the adjudication order and not in the SCN. The matter was accordingly placed before High Court.

High Court Held

The High Court held that Section 75(7) of the CGST Act mandates proper specification of demand in the SCN, including quantification of interest where the liability pertains to a known period. It observed that in the present case, the interest was ascertainable at the time of issuance of the SCN, and therefore, failure to quantify the same constituted a clear statutory violation. The Court further held that Section 75(9) could not be invoked to cure defects in the SCN, as it applies only to non-quantification in the adjudication order and not at the stage of initiation of proceedings. Accordingly, the impugned show cause notice and the consequent adjudication order were held invalid and quashed.

List of Cases Referred to

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NFRA Issues Six Inspection Reports on CA Firms to Strengthen Audit Quality

NFRA inspection reports

The National Financial Reporting Authority (NFRA), under its mandate prescribed in Section 132 of the Companies Act, 2013, has issued six new inspection reports on Chartered Accountant firms as part of its audit quality inspection initiative.

Section 132 entrusts NFRA with the responsibility of monitoring compliance with auditing and accounting standards, overseeing the quality of professional services, and recommending measures for improvement. In line with this mandate, NFRA commenced its latest round of audit quality inspections in March 2025, following the procedures laid down in the NFRA Rules, which include evaluation of auditors’ quality control systems and documentation practices.

The primary objective of these inspections is to assess whether audit firms are complying with regulatory and professional requirements and whether their quality control systems are adequate and effective. This includes evaluating the governance framework of firms, the effectiveness of internal controls over audit quality, and the processes for identifying and mitigating audit risks.

The inspection process involves a review of quality control policies, focused examination of key areas, and test checks of both quality control processes and selected audit engagements carried out during the year.

It is important to note that these inspections are intended to identify areas for improvement in audit firms’ quality control systems. They are not designed to provide a comprehensive review of all aspects of a firm’s operations, nor to identify every weakness in audit execution. Similarly, the inspection reports are not meant to serve as ratings or marketing tools, but rather as a mechanism to enhance overall audit quality and professional standards.

Click the link below to access the inspection reports:

Inspection Report 1

Inspection Report 2

Inspection Report 3

Inspection Report 4

Inspection Report 5

Inspection Report 6

Click Here To Read The Full Story

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GST Arrest Invalid for Non-Compliance with BNSS Notice | HC

BNSS section 35 arrest

Case Details: Sameer Malik vs. Union of India - [2026] 184 taxmann.com 550 (Gauhati)

Judiciary and Counsel Details

  • Pranjal Das, J.
  • Ms S.K. Nargis, Adv. for the Appellant.
  • S.C. Keyal, learned Standing Counsel for the Respondent.

Facts of the Case

The petitioner was subjected to arrest by the Anti-Evasion Unit in connection with an investigation alleging issuance of fake invoices and wrongful availment of Input Tax Credit (ITC) through non-existent firms. Prior to such arrest, a notice under section 35(3) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) was issued requiring the petitioner to appear before the investigating officer at a specified time on the same day. However, the petitioner was arrested before the scheduled time of appearance, and it was contended that such action was taken without recording any reasons for bypassing the statutory procedure prescribed for securing appearance. The petitioner sought bail on the ground that there was non-compliance with the mandatory procedural safeguards, while the investigating officer (IO) admitted that the timing mentioned in the notice was erroneous but failed to justify the premature arrest. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the procedural safeguards embodied under section 35(3) of the BNSS, akin to those under section 41A of the Code of Criminal Procedure, were applicable to arrests made in connection with offences under section 69 read with section 132 of the CGST Act. It was observed that in cases where an arrest is effected without ensuring compliance with the notice procedure, the investigating officer is required to record valid reasons for such deviation. The Court noted that since the arrest was effected prior to the time fixed for appearance on the same day, the notice could not be said to have been effectively complied with, thereby rendering the arrest procedurally defective. In the absence of any justification for such deviation, the arrest was held to be infirm in law. Consequently, the petitioner was held entitled to a grant of bail.

List of Cases Referred to

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RBI Caps Offshore INR Positions at $100 Million

Offshore INR Positions

RBI/2025-26/252 A.P. (DIR Series) Circular No. 24; Dated: 27.03.2026

1. Regulatory Background

As per the Master Direction dated July 5, 2016, the Reserve Bank of India (RBI) is empowered to prescribe limits on Net Open Position in INR (NOP-INR) for effective exchange rate management, depending on prevailing market conditions.

2. New Direction Issued by RBI

In line with this framework, the RBI has directed Authorised Dealers (ADs) to maintain their NOP-INR positions in the offshore deliverable market within a specified limit.

3. Prescribed Limit

  • ADs must ensure that their NOP-INR positions do not exceed US$ 100 million
  • This limit is to be maintained at the end of each business day

4. Applicability & Compliance Timeline

  • The direction applies to all Authorised Dealers participating in offshore deliverable markets
  • ADs are required to ensure compliance at the earliest, but no later than April 10, 2026

5. Key Takeaway

This move reflects RBI’s continued focus on prudential risk management and exchange rate stability by placing tighter controls on offshore INR exposures held by market participants.

Click Here To Read The Full Circular

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RBI Issues RBI (Unique Identifiers in Financial Markets) Directions 2026

RBI LEI UTI Directions 2026

Circular no. RBI/FMRD/2025-26/392 FMRD.MIOD.No.9/11.01.057/2025-26; Dated: 27.03.2026

1. Introduction

The Reserve Bank of India (RBI) has issued the RBI (Unique Identifiers in Financial Markets) Directions, 2026, laying down a comprehensive framework for the use of unique identifiers in financial market transactions.

2. Coverage of the Directions

The Master Directions prescribe norms relating to:

  • Scope and applicability of the Legal Entity Identifier (LEI)
  • Framework for implementation of LEI
  • Scope of the Unique Transaction Identifier (UTI)
  • Framework for implementation of UTI

3. Legal Entity Identifier (LEI) – Key Aspects

The LEI is a 20-character unique identity code assigned to entities participating in financial transactions.

3.1 Mandatory Requirement

  • All participants—resident and non-resident—falling within the scope must obtain an LEI
  • LEI must be obtained from a Local Operating Unit (LOU) accredited by the Global Legal Entity Identifier Foundation (GLEIF)

3.2 Compliance Conditions

  • Entities without an LEI are not permitted to undertake transactions in RBI-regulated financial markets
  • The LEI must remain active and up to date as per global LEI system rules
  • Lapsed or inactive LEIs will render entities ineligible for transactions

4. Unique Transaction Identifier (UTI) – Key Aspects

The UTI is a unique identifier assigned to each OTC derivative transaction.

Applicability

  • Mandatory for all transactions in the OTC derivatives market
  • Must be generated and reported in accordance with the Governing Directions

5. Key Takeaway

These Directions strengthen transparency and traceability in financial markets by mandating standardised identifiers for both entities (LEI) and transactions (UTI), thereby enhancing regulatory oversight and systemic risk monitoring.

Click Here To Read The Full Circular

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No Additions Without Valid 65B Certificate | ITAT

Section 65B electronic evidence

Case Details: Deputy Commissioner of Income-tax vs. Balar Marketing (P.) Ltd. - [2026] 184 taxmann.com 480 (Delhi-Trib.)

Judiciary and Counsel Details

  • Anubhav Sharma, Judicial Member & Manish Aggarwal, Accountant Member
  • Rajiv Khandelwal, CA, Jaind Kumar JaiswalGagan R. Khandelwal, Advs. for the Appellant.
  • Jitender Singh, CIT-DR for the Respondent.

Facts of the Case

The assessee was a private limited company. A search was conducted at the premises of the assessee company’s administrative head. As a result of the search, two mobile phones were seized. Analysis of digital data extracted from these phones revealed WhatsApp/SMS chats and certain images of one software.

Assessing Officer (AO) examined said images and chats, which allegedly reflected the exchange of cash tokens through a hawala network, and concluded that the assessee had effected cash sales to various parties. He made additions over the years based on such electronic data and statements. The matter reached before the Delhi Tribunal.

ITAT Held

The Delhi Tribunal held that the incriminating material relied upon by the Assessing Officer was not primary evidence, as the original software was neither found nor retrieved from any device. The material consisted solely of images allegedly shared for transaction acknowledgement. Further, WhatsApp chats contained only numerical figures, allegedly treated as coded entries, without independent narration of transactions.

The copy of the 65B certificate, purportedly issued by the administrative head, was merely a certificate of expertise regarding the due process adopted. At the same time, the data was backed up from the impugned devices to devices that were cloned. However, subsequently, as to how data was retrieved, and relevant incriminating evidence was extracted from devices by whom, had not been certified.

Since images on mobile devices constitute secondary evidence, any reliance on them necessitates strict adherence to the Board’s instructions for establishing authenticity. In the present case, the absence of a proper extraction report, a valid certificate under section 65B, and an adequately documented chain of custody rendered the electronic evidence inadmissible. Accordingly, additions made solely based on such unauthenticated material could not be sustained.

List of Cases Reviewed

List of Cases Referred to

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Practical Insights on Ind AS and SAs | Strengthening Framework & Institutional Support

Ind AS implementation framework

Editorial Team – [2026] 184 taxmann.com 596 (Article)

Taxmann presents Practical Insights on Ind AS and SAs, a weekly series exclusively for Accounts and Audit Module subscribers of Taxmann.com, focusing on the practical application of Ind AS and Standards on Auditing through structured, issue-based analysis.

Each week features a focused topic with real-world illustrations. This edition examines the evolving framework for Ind AS implementation in India, with a focus on regulatory developments, conceptual foundations, and institutional mechanisms supporting its practical application across sectors.

1. Introduction

The development of financial reporting in India shows how national economic policies are aligned with global capital market expectations. The Ministry of Corporate Affairs (MCA), as the main regulator of companies, has implemented a phased move to Indian Accounting Standards (Ind AS), taking into account the size and complexity of different sectors. The Ind AS roadmap lays down three criteria to determine applicability for non-financial companies. A company must apply Ind AS if it meets any one or more of the following:

(a) the net worth criterion, where companies with a net worth of INR 500 crores or more (Phase 1, from 1 April 2016) or INR 250 crores or more (Phase 2, from 1 April 2017) are required to comply;

(b) the listing criterion, where all listed companies must follow Ind AS, with phase classification based on net worth; and

(c) the relationship criterion, where holding, subsidiary, associate, or joint venture companies of entities already covered under Ind AS are also required to apply Ind AS.

Once a company begins applying Ind AS based on these criteria, it must continue to follow Ind AS for all subsequent financial statements, even if it no longer meets the criteria. Further, a company required to comply with Ind AS must apply the same standards to both standalone and consolidated financial statements and cannot choose to apply Ind AS only to one of them. This transition also includes a structured roadmap for financial and non-financial companies, the process for first-time adoption under Ind AS 101, First Time Adoption of Indian Accounting Standards and its wider legal and regulatory implications.

This article explains the applicability and implementation of Ind AS in India, covering key principles, regulatory roadmap, and conceptual framework. It also highlights the role of ITFG in resolving practical implementation challenges.

2. General Instructions under the Ind AS Notification, 2025

The evolution of financial reporting in India represents a sophisticated alignment of national economic policy with global capital market expectations. The Ministry of Corporate Affairs (MCA), in its capacity as the primary regulator for corporate entities in India, has orchestrated a phased migration that accounts for the varying sizes and complexities of different industrial and financial sectors. It provides an exhaustive analysis of the regulatory roadmaps for non-financial and financial companies, the technical mechanics of first-time adoption governed by Ind AS 101, and the broader statutory implications of this transition.

The transition to Ind AS was catalysed by India’s commitment at the G20 summit to converge its national standards with the International Financial Reporting Standards (IFRS) issued by the International Accounting Standards Board (IASB). The objective was to create a single set of high-quality, global accounting standards that would enhance the comparability, transparency, and credibility of financial statements for international investors. While an initial attempt to converge was planned for 2011, several factors, including unresolved tax issues and the readiness of the corporate sector, led to a deferral.

The current regime was revitalised following the 2014 Union Budget speech by the finance minister, which emphasised the urgent need for a converged framework to put India at the centre stage of global financial reporting. Consequently, the MCA notified the Companies (Indian Accounting Standards) Rules, 2015, on February 16, 2015, providing the statutory foundation for a mandatory, phased rollout of 39 initial Ind AS standards. These standards are “converged” rather than “adopted” versions of IFRS, meaning they include specific “carve-outs” (departures from IFRS) and “carve-ins” (additions) tailored to the Indian economic and legal environment.

The said notification prescribes three General Instructions that govern the overall application of Ind AS:

(a) Instruction 1 – Supremacy of Law over Ind AS – Ind AS are designed to be in conformity with applicable laws. However, where a subsequent legislative amendment creates a conflict between a particular Ind AS and the law, the provisions of the law shall prevail. In such cases, financial statements must be prepared in conformity with the relevant law, notwithstanding the requirements of the applicable Ind AS.

(b) Instruction 2 – Materiality – Ind AS are intended to apply only to items that are material. Immaterial items are not required to be accounted for or disclosed in strict compliance with a particular standard, consistent with the overarching principle of materiality in financial reporting.

(c) Instruction 3 – Equal Authority of Bold and Plain Text – Each Ind AS comprises paragraphs in both bold italic type and plain type both carry equal authority. Paragraphs in bold italic denote the main principles of the standard. Every Ind AS must be read in the context of its stated objective and in accordance with these General Instructions.

These three instructions lay the foundational interpretive framework within which all individual Ind AS are to be read and applied.

3. Key Principles Governing the Applicability and Continuity of Ind AS under the Companies (Indian Accounting Standards) Rules 2015

The applicability of Indian Accounting Standards (Ind AS) under the Companies (Indian Accounting Standards) Rules, 2015, extends beyond mere threshold-based compliance and introduces a comprehensive framework governing the continuity, scope, and manner of financial reporting. Once an entity becomes subject to Ind AS i.e. whether through mandatory criteria or voluntary adoption, the implications are far-reaching, affecting not only the entity itself but also its group structure, including subsidiaries, associates, and joint ventures, both domestic and overseas.

In this context, certain key principles such as the irrevocable nature of Ind AS adoption, the reporting requirements for overseas entities, and the independent applicability of Ind AS to Indian subsidiaries of foreign parents play a crucial role in ensuring consistency, transparency, and uniformity in financial reporting across entities and jurisdictions.

(a) The Rule of Irrevocability – A critical legal provision of the Companies (Indian Accounting Standards) Rules, 2015, is the principle of irrevocability. Once an entity chooses to report its financial statements under Ind AS, whether voluntarily or mandatorily, it is prohibited from reverting to the previous IGAAP framework. This ensures consistency and prevents entities from switching back to IGAAP to avoid the more stringent measurement and disclosure requirements of Ind AS.

Even if a company starts following Ind AS due to mandatory Ind AS adoption criteria, it is required to follow Ind AS for perpetuity even if that company no longer meets any of the Ind AS applicability criteria.

(b) Financial Reporting for Overseas Entities – While an overseas subsidiary, associate, or joint venture may continue to prepare its standalone financial statements under the local laws of its specific jurisdiction, the reporting requirements for the Indian parent are distinct. If the Indian parent company falls under the Ind AS mandate either through meeting the net worth thresholds or by voluntary adoption, the overseas entity must provide a reporting package or financial statements aligned with Ind AS. This is essential for the parent company to fulfil its obligation of preparing Consolidated Financial Statements (CFS) in accordance with Ind AS.

(c) Reporting Obligations for Indian Subsidiaries of Foreign Parents – If an Indian company functions as a subsidiary, associate, or joint venture of a foreign corporation, it does not automatically default to the parent’s accounting framework. Instead, the Indian entity must assess its own Ind AS applicability criteria independently. If it meets the prescribed net worth thresholds (or opts for voluntary adoption), it is required to prepare its financial statements under Ind AS, notwithstanding the GAAP followed by its foreign parent.

Click Here To Read The Full Article

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Admitted Income Can’t Be Disputed Without Retraction | HC

admitted income retraction

Case Details: Narayan Rao Hebri vs. Assistant Commissioner of Income-tax - [2026] 184 taxmann.com 441 (Karnataka)

Judiciary and Counsel Details

  • S.G. Pandit & K. V. Aravind, JJ.
  • K.K. Chythanya, Sr. Counsel & Tata Krishna for the Appellant.
  • Y.V. Raviraj, Sr. Standing Counsel for the Respondent.

Facts of the Case

The assessee was engaged in real estate business. A survey under section 133A was conducted, and the assessee, by letter dated 29.09.2016, volunteered to offer a sum of Rs. 1,14,20,100 as additional income. The assessee filed the return of income for the relevant year and paid the corresponding taxes.

The return of income was selected for scrutiny to examine the payment of Rs. 24,00,000 made in cash during November 2016 towards income tax and the source thereof. The Assessing Officer (AO) treated both the unexplained cash and the sum declared during the survey as income from other sources and subjected them to tax at a rate of 60%.On appeal, the CIT(A) confirmed the additions made by the AO, and the Tribunal upheld the CIT(A)’s order. The matter then reached the Karnataka High Court.

High Court Held

The High Court held that the assessee contended that the additional income was admitted in the return on account of coercion exercised during the survey and based on the letter dated 29.09.2016, which, according to the assessee, was forcibly obtained by the Assessing Officer.

The assessee filed the return of income under section 139(1) and had the statutory opportunity to revise the return under section 139(5). Admittedly, the assessee neither retracted the letter dated 29.09.2016 admitting the additional income nor revised the return of income. The assessee also paid tax on the income so admitted.

Further, when the assessment was completed by adding the additional income and subjecting it to tax at the rate of 60%, the assessee, in the appeal before the CIT(A), challenged only the applicability of Section 115BBE, not the taxability of the additional income itself. For the first time before the Tribunal, the assessee contended that the additional income declared was based solely on a statement recorded during the survey and was unsupported by any evidence. The Tribunal rejected the said contention.

List of Cases Reviewed

  • Order dated 22.05.2025 passed in ITA No.2051/Bang/2024 by the Tribunal [Para 20] Affirmed

List of Cases Referred to

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