S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Income deemed to accrue or arise in India-Royalty-Fees for technical services-Tax residency certificate-Reply filed by the assessee was had not been properly considered-Orders set aside-DTAA-India-Singapore-USA [S.9(1)(vi), 9(1)(vii),148A(b), 148A(d), Art. 12, Art, 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessing Officer issued on assessee notices under section 148 dated 8-4-2021 seeking to reopen assessment for assessment years 2015-16 and 2016-17-Mandatory procedure of a prior inquiry under section 148A had not been followed-notices were unsustainable in law and quashed-Sanction-Sanction of Additional Commissioner and not only from Principal Chief Commissioner-Notice was quashed. [S. 148, 151, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Entry operator-Monetary limit of less than 50 lakhs-Subsequent information-Writ petition was dismissed.[S. 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accommodation entries-No reply was filed-Disputed facts-Writ petition was dismissed.[S.133(6) 148A(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued after more than six years-non-compliance with mandatory requirements-Period had not got extended by Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020-Notices dated 1-4-2021 and 5-4-2021 were held to be bad in law. [S. 148, 149, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Not granting the time prescribed from 7 to 30 days-Oder was set aside. [S. 148A(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accommodating entries-Investigation revealed that the transaction was merely accommodating entries-Reopening of assessment is held to be valid. [S. 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation-Notice issued in the name of a company which was amalgamated with Assessee (amalgamated company) and was not in existence on date of issue of such notice-The notice and consequent order is held to be invalid. [S. 148, 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Second notice-After High Court remanded the matter.-Second notice is bad in law. [S. 153(6)(i), Art. 226]

S. 147 : Reassessment-Within four years-Change of opinion-Compensation payable-Based on record that was already with the Assessing Officer at the time of the proceedings-Reassessment notice and order disposing the objection was quashed..[S. 37(1), 143(3), 260A]