S. 147: Reassessment-Notice for reassessment to examine the issue of depreciation already examined by the AO during the course of original assessment is untenable and liable to be quashed-SLP dismissed on account of delay of 426 days as well as on merits. [S. 32, Art . 136]

S. 147: Reassessment-Notice issued on the ground that dividend income does not qualify for exemption under section 10 (34) of the Act-issue of exemption claimed by the assessee was duly examined during the original assessment proceedings-notice is based on change of opinion and the same is void ab initio-SLP dismissed on account of delay of 124 days as well as on merits. [S.10(34), 115-O, Art . 136]

S. 147: Reassessment-Reassessment notices issued merely on the basis of third-party search information, without any material linking the assessee to the alleged escaped income and with reasons recorded mechanically without independent application of mind, are invalid and quashed; SLP dismissed. [S. 69, 132, 148 Art. 136]

S. 147 : Reassessment-Within four years-Audit objection-CSR expenditure-Notice and order disposing of the objection were quashed by the High Court-SLP of the revenue dismissed. [S. 37(1) 148, Art, 136]

S. 147: Reassessment-Lease rent-Unrealised gain-Depreciation-Absence of fresh tangible material-Reopening cannot be initiated on repetitive lease rent transactions accepted in past scrutiny assessments, unearned/unrealized foreign exchange hedging variations, or by applying prospective amendments on goodwill depreciation retroactively-SLP of revenue dismissed. [S. 32(1), 37(1),43(6) (c), 148, Art. 136]

S. 145: Method of accounting-Income-Accrual-Real income theory-Interest accrued on NPA loans is taxable where the assessee’s own conduct, such as extending further credit to the same borrowers, shows a realistic prospect of recovery; RBI Prudential Norms do not govern taxability under the Income-tax Act. [S. 4, 5]

S. 144C: Reference to dispute resolution panel-Time limit-Final assessment order to be passed within one month from the end of the month in which the directions of the Dispute Resolution Panel are received-Order passed about five months late-Timeline is mandatory-Order, computation sheet and demand notice quashed. [S. 143, 144B, 156]

S. 144B : Faceless Assessment-Failure to provide personal hearing through video conferencing against proposed variation and video conference was duly scheduled-Assessing Officer passed final order before such hearing-Order violated section 144B(6)(vii) and principles of natural justice-Order was quashed and set aside . [S. 143(3),144B(6)(vii), Art . 226]

S. 143(3): Assessment-Non-existing entity-Order passed in the name of non-existing amalgamated entities despite revenue’s knowledge-Application for additional evidence under Order XLI Rule 27 of CPC allowed-SLP dismissed. [S. 143, 260A, CPC Order XLI Rule 27, Art. 136]

S. 139: Return of income-Condonation of delay-Return uploaded eight minutes late owing to portal issues-Carry forward of business loss of about Rs. 21.33 crores denied under section 80-Minimal delay condoned to prevent grave hardship. [S. 44AB, 80, 119(2)(b), 139(1), Art. 226]