S. 148 : Reassessment-Notice-Direction of Supreme Court-UOI v. Ashish Agarwal-Pertaining only to notices issued after 1-4-2021 (2022) 444 ITR 1 (SC)-Notice issued prior to that date and after six years from assessment Year-Notices and proceedings are quashed. [S. 147, Art. 226]
S. 148 : Reassessment-Notice-Death of assessee was notified to Department-Notice in the name of the dead person-Subsequent notice issued on the legal heir of deceased-Notice and consequential orders set aside. [S. 147, 159(2)(b), 292B, Art. 226]
S. 148 : Reassessment-Notice-Amalgamation-Amalgamating Company ceases to exist-Notice and initiation of reassessment proceedings void ab initio-Permanent Account Number Of Non-Existent entity remaining active. [S. 147, 156, Art. 226]
S. 148 : Reassessment-Notice-Jurisdiction-Notice issued by Officer who had no jurisdiction over assessee-Not curable defects-Notice and order rejecting objections was quashed and set aside. [S. 147, Art. 226]
S. 147 : Reassessment-Double taxation avoidance agreements-Tax Residency Certificate granted by another country-Binding on Income-Tax Authorities in India-Notice of reassessment is not valid-DTAA-India-Singapore. [S. 90(2), 133(6), 148, Art. 13(4), Art. 226]
S. 147 : Reassessment-Change of opinion-Notice and order-disposing the objection was quashed. [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Sale of shares-Oversight of the Assessing officer-No failure to discloses material facts-Reassessment notice and order disposing the objection was quashed. [S. 54EC, 148, 153A, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Change of opinion-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]
S. 147 : Reassessment-Change of opinion-Facts available in the original assessment proceedings-Reassessment is not valid. [S. 143(3), 148, Art. 136]
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Assessee is not required to state law which department feels attracted. [S. 148, Art. 136]