S.147: Reassessment-After the expiry of four years-Business connection-Survey-Failure to deduct tax at source-Except for one, all other affiliates did not have a Permanent Establishment in India-Reassessment notice and order disposing the objection is quashed OECD Model Convention-Art. 5. [S.9(1)(i)),40(a(i), 133A, 148 195,201(1), Art. 226]

S.147: Reassessment-After the expiry of four years-Cash credits-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed and set aside.[S.68,147, Art.226]

S. 147 : Reassessment-After the expiry of four years-No failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment-Reopening of the completed assessment on the basis of same set of facts and on mere change of opinion based on an internal audit of the Revenue’s functioning held illegal and quashed-Sanction is given without application of mind-Reassessment is quashed. [S. 148, 151, Art. 226]

S. 144C : Reference to dispute resolution panel-Assessment Limitation-Assessment order is beyond limitation-Pending for final hearing-Assessment order passed under section 143(3) read with section 144C(3) and section 144B as also consequent demand notice and penalty proceedings were to remain stayed. [S. 143(3), 144B, 144C(3), Art. 226]

S.147: Reassessment-After the expiry of six years-Accumulation of income-No failure to disclose material facts-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S.11(3A) 12AA, 148, Form No 10, Art. 226]

S. 144C: Reference to dispute resolution panel-DRP has power to rectify its directions under section 154 of the Act.[S.154, 260A]

S. 144C : Reference to dispute resolution panel-Assessing Officer is mandated to pass final assessment order within time stipulated under S. 144C (4) of the Act-The fact that assessee had not filed objections before DRP within stipulated time is immaterial. [S. 144C (2), 260A].

S. 144B : Faceless Assessment –Principle of natural justice-Failure to grant personal hearing-Video conferencing-Matter is remanded back to Assessing Officer to pass a fresh de novo order after giving personal hearing to assessee through video conferencing.[Art. 226, 227]

S. 144B : Faceless Assessment –Principle of natural justice-Failure to issue show cause notice-order of assessment was to be quashed and matter was to be remanded back to stage of issuance of show cause notice by Assessing Officer to assessee so as to enable assessee to request for personal hearing. Matter remanded.[S. 144(8), Art. 226]

S. 144B: Faceless Assessment-Show cause notice along with draft assessment order-Assessment order passed without consideration the adjournment application filed online-Against the principals of natural justice-Order is quashed and set aside-Matter is remanded back. [S.143(3), 144B(1) (vii), Art. 226]