S. 148 : Reassessment-Notice-Unsigned notice –Failure to file return-Writ petition held not maintainable for failure to follow procedure laid down in GKN Driveshafts case-Directed to file the return of income along with all objections, including the validity of the notice, before the Assessing Officer for disposal via a speaking order. [S. 139, Art. 226]

S. 148: Reassessment-Notice to non-existent entity-Amalgamation-Notice issued to an amalgamating company is invalid where the basis for reopening collapses. [S. 2(1B),147 292B, Art. 226]

S. 148 : Reassessment-Notice-Amalgamation-Non existing company-Notice to non-existent amalgamating company is fundamentally invalid-Error is not a mere procedural or clerical mistake that can be rectified under section 292B of the Income-tax Act, 1961. [S. 147, 292B, Art. 226]

S. 147: Reassessment-Within four years-Reason to believe-Intimation under S. 143(1)-Reopening notice based on a system-generated alert from the Non-Filer Management System (NMS) without independent application of mind is invalid. [S. 68,139, 143(1), 148, Art. 226]

S. 147: Reassessment-Change of opinion-Enquiry during original assessment-Where Assessing Officer has raised a specific query during original assessment proceedings to which the assessee has replied, the issue is deemed to have been examined-Reopening assessment on the very same issue, even if not discussed in the assessment order, constitutes an impermissible change of opinion. [S. 37(1), 142(1), 148, Art. 226]

S. 147 : Reassessment-Within four years-Change of opinion-Prior period expenditure-Order of tribunal quashing the reassessment is affirmed. [S. 37(1), 260A]

S. 147 : Reassessment-Reason to believe-Jurisdiction-Unexplained money-Notice based on fundamentally wrong facts pertaining to a different entity-Constitutes non-application of mind-Reopening invalid. [S 69A, 148, 151, Art. 226]

S. 147 : Reassessment-Charitable or religious trust –-Non-application of mind-Receipts from charitable activities mistaken for commercial income-Reopening notice based on mechanical reasoning and factual errors quashed. [S. 11, 143(1) 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years / Within four years-Reasons to believe-Reopening based on borrowed information from DRI or Justice M.B. Shah Commission Report without independent application of mind by AO is not permissible-Failure to disclose material facts cannot be alleged based on a subsequent Supreme Court ruling. [S. 148, Art. 226]

S. 147 : Reassessment-After expiry of four years-Scrutiny assessment-Where original assessment was completed after a detailed scrutiny of the assessee’s share transactions, a subsequent reopening of assessment on the same issue based on information regarding ‘client code modification’ is invalid, as there was no failure on the part of the assessee to disclose material facts fully and truly. [S. 68,143(3), 148, Art. 226]