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Daily Intelligence Capsule — 4 September 2026
Latest EditionLatest Edition — Friday, 4 September 2026ITAT Delhi Quashes Time-Barred Section 148 Reassessment Notice
Ravindra v. ITO Explained
Income Tax
The ITAT Delhi has quashed a Section 148 reassessment notice for AY 2015-16 issued three days beyond the six-year outer limit, and deleted the resulting Rs 27.81 lakh penalty.
Read the briefingOrissa HC: GST Appellate Authority Cannot Condone Delay Beyond Section 107(4)
Sri Balaji Metallics Explained
The Orissa High Court has upheld rejection of a GST appeal filed beyond the four-month outer limit under Section 107 of the CGST Act, holding that the taxpayer's own Form GST APL-01 declaration of the communication date is binding.
Read: Sri Balaji Metallics ExplainedDelhi HC Confirms ESOP Discount Deductible Under Section 37(1)
PVR Ltd Case Explained
The Delhi High Court has held that the discount on shares issued under an Employee Stock Option Plan or Employee Stock Purchase Scheme is deductible revenue expenditure under Section 37(1), following the Karnataka High Court's Biocon ruling.
Read: PVR Ltd Case ExplainedDid You Know
A reassessment notice quashed for missing its deadline by three days
When the Finance Act, 2021 rewrote the reassessment regime, it fixed a hard six-year outer limit for AY 2015-16 — a Section 148 notice dated 3 April 2022 missed it by three days, and the Tribunal quashed the whole assessment plus the Rs 27.81 lakh penalty.
Read: A reassessment notice quashed for missing its deadline by three days