S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Best judgment assessment-Faceless assessment-Jurisdictional Assessing Officer has no jurisdiction to issue notice for reassessment in faceless mechanism-Notices and order is quashed. [S. 144, 144B,144C(1), 148, 148A(b) 148A(d), 151A(1) Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Failure to respond initial notices-Stoppage of business-Notice was not sent to existing E.mail-Matter remanded to the Assessing Officer for reconsideration and decide in accordance with law. [S. 147 148, 148A(b) 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless Assessment-Notice issued by Jurisdictional Assessing Officer-Similar issue pending before Supreme Court-Stay is granted till order to be passed by Supreme Court. [S. 147, 148, 148A(b) 148A(d), 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless Assessment-Central charges and International Taxation charges-Notices issued and order passed by Jurisdictional Assessing Officer outside purview Of faceless mechanism-Notices and order illegal and without jurisdiction and hence set aside. [S. 119, 147, 148, 148A9(b) 148A(d) 151A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice after three years-Failure to file the return of income-Gross receipt of sale consideration not income chargeable to tax-Notice and consequential orders are quashed-SLP of Revenue is dismissed.[S. 2(24), 147, 148A(b), 148A(d), Art. 136]

S. 147 : Reassessment-After the expiry of four years-Search and Seizure-Trust-Wholly-Capitalisation fee-Statement of managing trustee under oath accepting receipts of capitation fee-Order of Settlement Commission for subsequent year-Order of Tribunal quashing the reassessment is held to be erroneous and set aide.[S. 10(23C)(iv), 11, 12, 12A, 12AA, 132, 148, 245D(6), 260A]

S. 147: Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Notice and order disposing the objection is quashed-Delay of 429 days in filing SLP. SLP of Revenue is dismissed as the reasons assigned for explaining the delay are neither satisfactory nor sufficient. [S. 148, Art. 136]

S.143(3): Assessment-Transfer Pricing-Arm’s length price International Transactions-Limitation-Service of notice-Order of Transfer Pricing Officer is not signed digitally or manually before limitation Circular dated February 2018 (2018) 401 ITR (St) 176-Order is not valid.[S.92C, 119, 144C, Art. 226]

S.143(3): Assessment-Income above 30 lakhs-Validity of notice issued u/s 143(2)-Instruction of CBDT 1 of 2011-Defective notice-Notice and proceedings invalid. [S.119, 143(2)]

S. 143(3): Assessment-Rejection of books of account-Business Expenditure-Deduction of tax at source-Failure to substantiate expenditure with documentary evidence-Assessment of income at 12 Per Cent-On total disclosed revenue based on material available on record brought to knowledge of Assessee in notice-Writ petition is dismissed-All contentions of assessee is left open to be raised before Appellate Authority.[S. 40(a)(ia), 144B, 194C, 270A, Art. 226]