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]

S. 143(3): Assessment-Rejection of books of account-Business Expenditure SLP against dismissal of writ petition is dismissed-Clarified that in the event the assessee filed an appeal, the Commissioner (Appeals) shall examine all issues and contentions on the merits without being influenced by any of the observations made by the High Court. [S. 40(a)(ia), 144B, 194C, 270A, Art. 136]

S. 139 : Return of income-Revised return of income-Bar of limitation-Revised return was filed after expiry of prescribed time-Tribunal directing Assessing Officer to consider Assessee’s claim made in revised return-Order of Tribunal is set aside-Order of Assessing Officer confirmed by Commissioner (Appeals) is restored. [S. 139(5), 143(1)(a), 143(2), 254(1), 260A]

S. 139 : Return of income-Revised return of income-Bar of limitation-Revised return was filed after expiry of prescribed time-Tribunal directing Assessing Officer to consider Assessee’s claim made in revised return-Order of Tribunal is set aside by the High Court-Order of Assessing Officer confirmed by Commissioner (Appeals) is restored-Appeal of assessee is dismissed. [S. 139(5), 143(1)(a), 143(2), 254(1), Art. 136]