HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Principal Commissioner of Income Tax, Central-3 v Abhisar Buildwell P. Ltd.
Miscellaneous Application No. 680 of 2023 in Civil Appeal No. 6580 of 2021
No separate citation stated in the source ·
147 · 148 · 150 · 153A · 153C
Sources & disclosures includedDownload original judgment / order
2 Judges · M.R. Shah · Sudhanshu Dhulia
01 · Facts of the case
The Revenue sought clarification following the Abhisar Buildwell decision, including how section 150(2) would operate, whether reassessment could cover non-incriminating-material income and whether fresh proceedings could commence within 60 days. These were requests by the applicant, not directions already granted by the Court.
Source: paragraphs 1 / PDF pages 1, 2, 3
02 · Discussion by the Hon’ble Court
The Court regarded the relief sought as review requiring detailed consideration. It declined to entertain the application in the form of clarification and expressly avoided deciding the prayers on their merits.
Source: paragraphs 2-3 / PDF pages 3, 4
03 · Judicial decision
The miscellaneous application was disposed of without entertaining the clarification. The Revenue was left to file an appropriate review application, to be heard in open court and determined on its own merits if filed.
Source: paragraphs 2-3 / PDF pages 3, 4
04 · Outcome / in whose favour
In whose favour: No merits winner
Clarification application not entertained; recourse to review left open
Procedural only; no reassessment or limitation relief decided
Neither the requested 60-day window nor a limitation waiver was granted by this judgment. It is separate from the substantive Abhisar Buildwell judgment.
Source: paragraphs 3 / PDF pages 3, 4
05 · AKHB REVIEW POINT
Do not cite the applicant’s quoted prayers as a Supreme Court permission to reopen assessments. Before using the Abhisar line of cases, inspect the principal judgment and any later review outcome separately. This four-page judgment records only the procedural route for seeking the additional relief.
Source & verification
Download original judgment / order · Open cited source rendition
Complete identified source PDF: 4 pages. Original bytes preserved.
- Subsequent review outcome not verified
- The underlying substantive judgment must be a separate record; this application must not substitute for it
- Not stated in this application judgment
- These provisions arise in the Revenue’s requested clarification; their merits were expressly not adjudicated in this judgment.
Statutory scope
This review describes the statutory version applied by the Court. Later amendments and 2025 Act correspondence require separate checks.
Later treatment
Source checked 2026-10-04. Subsequent appeals, review proceedings, stays, reversals and later judicial treatment have not been comprehensively checked. This note is not a citator status certificate.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Identified source links
- official signed judgment — PDF 4 pages
SHA-256: cf643701dbca9f70bb3240fb82c3a17b6eec63e255082fdff215439f7f45bd93
Coverage, AI disclosure & professional disclaimer
Selected Supreme Court income-tax decisions and procedural orders checked against their identified sources. This collection is not exhaustive. The research catalogue has 2,569 indexed PDF assets, including alternate copies and incidental matches; that is not a count of unique or reviewed judgments. Historical and unreported coverage remains open.
AI-assisted research checked against the identified source. Extraction, interpretation or omission errors remain possible. Source review does not mean independent approval by a practising professional. Verify every material statement against the complete original judgment.
General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on facts, assessment year, statutory version and jurisdiction. Subsequent treatment is unverified unless a note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.
The official 1961–2025 structural correspondence does not establish that a precedent applies under the new Act. Verify the enacted wording, commencement and transitional provisions separately.