S. 147 : Reassessment–With in four years-Failure to disclose material facts-Fails to challenge the reopening at the appropriate time before the Court-Not entitled to seek such indulgence, after allowing the Officer to pass the order of assessment-Writ Court cannot sit as an Appellate Authority and decide the merits of the assessment-Writ is held to be not maintainable. [S. 148, Art.226]

S. 147 : Reassessment-Change of opinion-Business expenditure-Technical know how-Depreciation-TP adjustments were made in the original assessment proceedings-Reassessment is held to be not valid. [S. 32(1)(ii), 37(1)]

S. 147 : Reassessment—Change of opinion-Original return processed by intimation No failure to disclose truly and fully all material and no new tangible material available with AO Reassessment is held to be not valid. [S. 143(1), 143(3), 148]

S. 147 : Reassessment-Capital gains-Year of taxability-Transfer of land under Development agreement-Amounts received offered to tax as capital gains and assessed for AY. 1999-2000 up to 2003-04-No adjudication regarding date of effective transfer of land- Reassessment is valid–Tribunal while granting the relief ought to have granted consequential reliefs-AO is directed to give relief for AY.1999-2000 to 2003-04. [S.45, 148, 154, 254(1)]

S. 147 : Reassessment-Bogus transactions-Accommodation entries-bogus long term capital gains-Sale of shares-Report by investigation wing–Search of third person-Reasons can be explained further in affidavit-Reasons Can Be Explained Further In Affidavit—Notice of reassessment is held to be valid. [S. 45, 148, 153A(1)(b), Art. 226]

S. 147 : Reassessment-Report of Investigation wing of Income-Tax Department-AO analysing report and forming belief that income had escaped assessment-Reassessment notice is valid. [S.148, Art. 226]

S. 147 : Reassessment–Based on facts of later assessment year– Tangible material-Reassessment is held to be valid-Income derived from installation and maintenance of Atm Machines—Not entitled to deduction u/s. 80IA. [S. 80IA, 143(1), 143(3), 148]

S. 147 : Reassessment-Capital gains–Cash sales-Failure to disclose material facts – Notice of reassessment is held to be valid. [S. 45, 48 148, Art.226 ]

S. 147 : Reassessment-Notice-Non disposal of assesses objections-Direction u/s 144A-Assessment without disposing the objection is held to be bad in law-AO is directed to pass the reasoned order after considering the objection. [ S. 144A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Amounts not deductible-Deduction at source–Objection by audit party– Reassessment at the instance of the Audit officer is held to be bad in law. [S. 40)(a)(ia), 148]