Andhra Pradesh High Court Judgments — 2026

The High Court held that Section 147A of the Income Tax Act, 1961, introduced by the Finance Act, 2026, is unconstitutional and struck it down. The Court reasoned that the Finance Act, 2026, received the President's assent on March 30, 2026, but expressly came into force from April 1, 2026. Therefore, any amendment or insertion made to a repealed Act (as implied by the retrospective application) was not sustainable. The Court cited the Supreme Court's judgment in 'Common Cause Vs. Union of India and others' to support the principle that an Act comes into force on the date expressly provided, or if not specified, on the date of assent. Since Section 147A was found unconstitutional, all proceedings initiated by the JAOs under Sections 148A and 148, which were to be undertaken in a faceless manner, were deemed to be without jurisdiction and were set aside. The Court allowed the writ petitions and quashed the impugned proceedings/orders.

The High Court dismissed the appeal as withdrawn based on the CBDT Circular No. 9 of 2024, which specified a monetary limit for appeals. The court, however, kept the question of law involved open for adjudication in appropriate future proceedings.

The High Court upheld the ITAT's decision, agreeing that the appellant failed to prove the source of the alleged cash gifts from her grandmother. The court found inconsistencies in the appellant's explanations and a lack of evidence regarding the donor's creditworthiness and the genuineness of the transaction.

The High Court found that the ITAT had indeed considered the grounds raised by the assessee in its original order, contrary to the assessee's claim in the miscellaneous application. As the Tribunal had addressed the said grounds, the High Court found no reason to interfere with the ITAT's decision to dismiss the recall application.

The High Court found the reasons provided for the delay insufficient and lacking in specifics. The court opined that it was not permissible to condone such a significant delay without a plausible ground and detailed explanation.

The High Court held that assessment proceedings initiated by the Jurisdictional Assessing Officer were prohibited under Section 151A of the Income Tax Act, making the assessment orders invalid. Consequently, the appellate orders were also set aside.

The High Court dismissed the Income Tax Tribunal Appeal for default. It concluded that the appellant was not interested in prosecuting the appeal due to their consistent non-appearance.

The High Court dismissed the appeal for default as the appellant failed to appear for the hearings. The court noted the appellant's lack of interest in prosecuting the appeal.