S. 148 : Reassessment-Notice-Non-service of notice-E mail is sent to wrong address-Notice was not served within period of limitation-Notice in e-filing portal had to be considered as date of issuance of notice Reassessment is bad in law. [S. 115BBA,144, 147]

S. 148 : Reassessment-Notice-Notice issued by non-jurisdictional Assessing Officer-Notice and Assessment order is quashed. [S. 147]

S. 148 : Reassessment-Notice-Beyond human probabilities-Factual mistakes and errors in dates mentioned on notice-Assessment order is void ab-initio-Notice issued affixture through inspector without presence of two independent witnesses of neighborhood as per procedure laid down in section 282 read with rules 12, 17 and rule 19 of Order V of Civil Procedure Code, 1908, such service of notice is invalid.[S. 147, 282, rules 12, 17 and rule 19 of Order V of Code of Civil Procedure, 1908,]

S.147: Reassessment-Cash credits-Provisions of IBC overriding effect-Department is bound by terms of resolution plan, as approved by NCLT and Income-tax Department was precluded from undertaking any action with respect to any issue/transaction prior to date of commencement of insolvency process in case of assesse.[S.68, 148, Insolvency and Bankruptcy Code, 2016, S.5, 31, 238]

S.147: Reassessment-After the expiry of four years-Information received from AIR-Cash deposited in bank-Considered in the original assessment proceedings-Reassessment is not justified.[S. 68]

S. 147 : Reassessment-After the expiry of four years-Book profit-Minimum alternate tax-Tax liability under MAT provisions remains higher and unchanged despite adjustments made under normal tax provisions-Reassessment is bad in law.[S.115JB, 148]

S. 144C : Reference to dispute resolution panel-Draft assessment order-After 1-10-2009, Assessing Officer is statutorily required to pass draft assessment order under section 144C(1)-Any addition is made before passing final assessment order under section 144C(3)is bad in law.[S. 144C(1), 144C(3)]

S. 144C : Reference to dispute resolution panel-Assessing Officer passed final assessment order in case of assessee on 21-11-2017 after one month from end of month in which he received directions of Dispute Resolution Panel i.e., 18-9-2017-Order is time barred hence quashed and set aside. [S.92CA,144C(13)]

S. 144C : Reference to dispute resolution panel-Limitation period-Date of uploading DRP order on ITBA portal was 27-4-2022-Assessment completed on 30-6-2022 is time barred as null and void. [S. 143(3), 144C((13), Information Technology Act, 2000, S.13]

S. 143(3) : Assessment-Revision order is quashed by Tribunal-Assessment order became infructuous. [S. 143(3), 254(1)]