Daily Intelligence Capsule — 13 September 2026

Latest EditionLatest Edition — Sunday, 13 September 2026

Income Tax

"Change of Opinion" Reaffirmed: Bombay HC Quashes a Six-Year-Late Reassessment on a Settled Section 54F Claim

Income Tax

The Bombay High Court has quashed a reassessment notice issued six years after a Section 54F capital gains claim was accepted, holding that an Assessing Officer need not discuss every issue for the law to treat it as examined.

Read the briefing

GST

No 'Reason to Believe': Karnataka HC Quashes GST Registration Cancellation Built on a Fabricated Field Report

The Karnataka High Court has quashed the cancellation of two GST registrations as "fake," holding that field-verification reports containing an unrelated property's photograph and a blank report cannot meet the statutory "reason to believe" standard.

Read: No 'Reason to Believe': Karnataka HC Quashes GST Registration Cancellation Built on a Fabricated Field Report

Case Law Watch

Gauhati HC Reaffirms Bona Fide Purchaser ITC Protection Across a Scrap-Trade Batch

The Gauhati High Court (Silchar Bench) has reaffirmed, across a batch of scrap and waste-battery dealer rulings, that bona fide purchasers cannot be denied Input Tax Credit merely because a supplier failed to deposit collected tax — a more conservative route to the same outcome the Supreme Court has stayed in Sahil Enterprises (final hearing 17 September 2026).

Read: Gauhati HC Reaffirms Bona Fide Purchaser ITC Protection Across a Scrap-Trade Batch

Case Law Watch

Karnataka HC: DGGI Probe Not Barred by a Prior State Inquiry

The Karnataka High Court has held that DGGI's central investigation into an alleged ₹100+ crore fake-ITC network is not barred by a prior State GST inquiry — mere information-gathering does not amount to "initiation of proceedings" under Section 6(2)(b) of the CGST Act.

Read: Karnataka HC: DGGI Probe Not Barred by a Prior State Inquiry

Did You Know

When the Bombay HC quashed a reassessment as "change of opinion"…

When the Bombay High Court quashed a reassessment this week as an impermissible "change of opinion," it didn't need the original assessment order to say much at all. The Court's own words: "it is not necessary for an Assessing Officer to discuss each and every issue elaborately to disclose his satisfaction." A short assessment order and an unexamined issue are two very different things in the eyes of the law.

Read: When the Bombay HC quashed a reassessment as "change of opinion"…

What's the Penalty?

Your client's GST registration is cancelled as "fake" on a field-verification report…

Your client's GST registration is cancelled as "fake" on a field-verification report that turns out to show a completely different property. Is the cancellation valid — and is the registration automatically restored for good if it isn't?

Read: Your client's GST registration is cancelled as "fake" on a field-verification report…