S.147: Reassessment-After the expiry of four years-Change of opinion-Direction of Audit party-Amalgamation-AO issued notice on the ground of directions issued by the audit party-Being not on AO’s personal satisfaction, reopening of assessment without any basis, merely on change of opinion and not permissible in law-Reassessment notice and order disposing the objection is quashed.[S. 72A(4), 148, Art. 226

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed.[S. (2(22)(e), 147, 148, Art. 226]

S. 144B: Face less assessment-Reassessment-Principle of natural justice-Technical glitch-Order is set aside.[S. 147, 148, Art.226]

S. 144B : Faceless Assessment-Video Conferencing not granted by the Assessing Officer-Grave abrogation of jus naturale-impugned assessment order is set aside.[S. 144B(6) (viii), 147, 148, Art. 226]

S. 144B : Faceless Assessment-Principles of natural justice-At least 21 days time should be given to file reply-Legislative Intent is to provide an opportunity of being heard to the assessee before passing any orders, which are prejudicial to their rights/interests-It is bounden duty of the Assessing Officer to pass a detailed order, providing reasons for rejection of the contention of the assessee-Matter restored to the file of the AO as the assessee was granted time of 5 days only without referring to opportunity of personal hearing.[Art. 226]

S.144B: Faceless assessment-Assessment order passed without issuing draft assessment order, matter remitted to pass a fresh order per law.[S. 148, Art. 226]

S. 143(3): Assessment-Principles of natural justice-Cross examination not granted by the Assessing Officer-Order of the Tribunal setting aside the assessment was upheld by the High Court. [S. 260A]

S. 143(3): Assessment-Assessment order passed in spite of valid objections pending before DRP is bad in law.[S.144C, Art. 226]

S. 143(3) : Assessment-Limited scrutiny-Issue decided by AO with respect to carry forward of losses was not part of limited scrutiny for which assessment was directed to be scrutinised, since AO did not abide by Instruction No. 5/2016, dated 14-07-2016 and exceeded his jurisdiction, disallowance made with respect to carry forward of losses was to be deleted.[S. 72, 260A]

S. 143(2): Assessment-Notice-Defective return-Date of filing of original return under section 139(1) was to be considered for purpose of computing period of limitation under sections 143(2) and 142(1), and not date on which defects actually came to be removed under section 139(9)-Notice is quashed. [S. 143(2), 139(1), 139(9)