S. 153C : Assessment-Income of any other person-Search-Cash credits-Accommodation entries-Pen drive-Transaction pertaining to financial year 2014-15-Satisfaction note for the Assessment year 2021-22-Pendrive cannot be considered as incriminating documents for the AY. 2021-22-Notice was quashed.[S.68, 132, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-No incriminating material had been gathered or obtained-Satisfaction notes also failed to record any reasons as to how material discovered and pertaining to a particular Assessment Year was likely to have a bearing on determination of total income for year which was sought to be abated or reopened in terms of notices-SLP filed by revenue against the order of High Court was dismissed on ground of delay of 250,, 215 and 267 days as well as on merits.[S. 132, Art. 136]

S. 153B : Assessment-Search and seizure-Time limit-Satisfaction note-date was required to be considered as 24-6-2022-Period available for making an assessment pursuant to notice dated 19-12-2023 would lapse on expiry of twelve months from end of financial year in which documents were handed over, that is, on 31-3-2024-The notice was quashed and set aside.[S. 132, 153C, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Notice was not issued with prior approval of Principal Chief Commissioner or any other authority specified under section 151(ii) which was a mandatory requirement-Notice was quashed and set aside. [S. 148, 148A(b) 148A(d), 151(1), 151(ii), Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Amount involved is more than Rs. 50 lakhs-Approval has to be obtained from Principal Chief Commissioner or Chief Commissioner as defined under section 151(ii)-Approval was obtained from Principal Commissioner in terms of section 151(i) and no approval was obtained before issuance of reopening notice in terms of provision of section 151(ii)-Reopening notice was quashed and set aside. [S. 148,149, 151(1), 151(ii), Art. 226]

S. 149 : Reassessment-Time limit for notice-Since only one day was available for issuance of notice, after giving opportunity of filing reply to assessee-Last date to issue notice as per judgment of Supreme Court in Rajeev Bansal would be 12-6-2022-Notice under section 148 was issued on 15-7-2022-Notice dated 30-6-2021 was an invalid notice Notice dated 15-7-2022 as well as notice dated 30-6-2021was quashed and set aside. [S. 148,148A(b), 148A(d), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). S.3, Art. 226]

S. 149 : Reassessment-Time limit for notice-Old regime-Notice dt 23-7 2022 seeking to reopen assessment for assessment year 2015-16-Following UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC) all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under TOLA-Accordingly the notice and proceedings are quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-Old regime-dated 1-6-2021 seeking to reopen assessment for assessment year 2015-16-Following UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC) all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under TOLA-Accordingly the notice and proceedings are quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-Long term capital gains from equities-Amount was below threshold limit of Rs. 50 lakhs-Notice was issued beyond period of limitation as prescribed under section 149(1)(a) and conditions as specified so as to attract provisions of section 149(1)(b) were not satisfied, same was set aside. [S. 148, 148A(b), 148A(d), 149(1)(a), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained expenditure-Bogus purcahses-Information received from GST department-Disregarding response furnished by assessee solely for reason of information on portal and simply reiterating information as available, would render procedure under section 148A meaningless-Accordingly reopening notice issued against assessee was set aside [S. 69C, 148A(b), 148A(d), Art. 226]