S. 147 : Reassessment-Change of opinion-Notice beyond period of limitation-Interest paid and interest received-Capital receipt-No failure on part of assessee to make true and full disclosure in original assessment-Reassessment proceedings to bring to tax interest receipts based on change of opinion impermissible.[S. 143(3), 148, 260A]

S. 147 :Reassessment-Assessment of third person-Authorised Officer conducting search to hand over seized documents relating to third person to Assessing Officer having jurisdiction within fifteen days of seizure-Assessing Officer seeking instructions from superior authority and not exercising independent judgment on facts-Reassessment proceedings and assessment order passed by Assessing Officer at dictation of higher authorities-Null and void. [S. 132, 132A(3), 147, 148, 153C, 260A]

S. 147: Reassessment-Unexplained investment-Assessment cannot be opened twice for the same reason-Reassessment notice and order disposing the objection is quashed and set aside. [S. 69, 148, Art.226]

S.147: Reassessment-After the expiry of four years-Interest on borrowed funds-Change of opinion-No failure to disclose material facts-Reassessment proceedings is quashed and set aside.[S. 36(1)(iii), 143(3), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Audit objection-Reassessment notice and order disposing the objection is quashed. [S. 57, 143(3), 147, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Material facts not considered-When the assessee’s objections to alleged foreign receipts are not adequately considered by the revenue authorities in response to a notice under section 148 of the Income-tax Act, 1961, a remand to the Assessing Officer is imperative. [S. 148, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Sanction should be given only after due application of mind-Notice and order disposing the objection is quashed. [S. 37(1), 148, 151, Art. 226]

S. 144C : Reference to dispute resolution panel-Not following mandatory requirements of section 144C(2)-Assessment Order cannot be treated as draft Assessment Order-Proceedings before DRP and Tribunal bad in law-Not curable defect-Defect cannot be cured by issuing corrigendum-Assessment order is void. [S. 144C(1)]

S. 144C: Reference to dispute resolution panel-Despatch-When electronic records enters portal or computer resource it is treated to be receipt by receipient Assessing Officer or concerned authority-The Assessment Orders were passed beyond the period of one month of receipt of directions by DRP, being barred by limitation, is set aside. [S. 144C(5), 144C (13) Information Technology Act, 2000-S. 2(k), Art. 226]

S. 144B : Faceless Assessment-Remand by Tribunal-Scrutiny assessment with certain disallowance u/s 14A-Remand by the Tribunal on the issues to JAO-The order giving effect to the ITAT’s directions passed by the JAO-The jurisdiction assumed subsequently by the NFAC on completed assessment by the JAO without jurisdiction and liable to be set aside. [S. 14A, 143(3), 147, 148, 254(1), Art. 226]