S. 149: Reassessment-Time limit for notice-Income escaping assessment was certainly more than Rs. one lakh. Notice dt. 31st March, 2021, issued under s. 148 within six years from the end of the asst. yr. 2015-16, falls within the time-limit of the old regime.-Notice through electronic platform on assessee’s email-ID-No illegality or invalidity either in the notice under s. 148 r/w s. 142(1) or at any stage of the assessment proceedings.[S.143(2), 144B,147, 148, 151]

S. 148: Reassessment]-Notice-Notice issued in the name of dissolved firm-No notice has been issued to any of the partners-Non existing entity-Notice issued in the name and address of the non-existing entity is in violation of S. 283(2), and it has no sanctity in the eyes of the law-Assessment order was quashed. [S.144B, 147, 189, 283(2)]

S. 148: Reassessment-Notice Limitation-Time-limit for issuing of notice under s. 148 for asst. yr. 2015-16 under the old provisions was 31st March, 2022-Notice issued on 28th June, 2021-Not covered under TOLA]-Barred by limitation. [S. 144C(13), 147, 149(1)]

S. 147: Reassessment]-Recorded reasons]-No addition was made based on recorded reasons. An issue that was not subject matter; no addition can be made.[S.68, 148]

S.147: Reassessment]-After the expiry of four years-No failure to disclose material facts-The essential conditions precedent to invoke the jurisdiction to reopen the assessment are absent-Consequently, issuance of notice under s. 148 is ab initio void.[S. 143(3), 148]

S.147: Reassessment]-After the expiry of four years-Information from the Addl. Director of IT(I&CI)-Interest income]-Excess loss of inventory in respect of obsolete stock-Reassessment was held to be valid. [S. 115JB, 148]

S. 144C: Reference to dispute resolution panel-Non-resident-Draft assessment order-Validity of assessment]-Eligible assessee]-[S.144C(15)(b), 147, 148]

S. 143(3): Assessment]-Limited scrutiny-Conversion of limited scrutiny into complete scrutiny without prior approval-Cash deposit-AO was obliged to take the specific permission of the Principal CIT before expanding the scope of enquiry to cover the credits in the assessee’s bank account-Failure to do so is a clear violation of the CBDT Instruction No. F. No. 225/402/2018/ITA.II, dt. 28th Nov., 2018-The addition made by him is not sustainable-Cash credit]-Reconciliation was filed]-Addition was deleted. [S.68]

S. 143(3): Assessment-Limited scrutiny-Addition made on other issues-AO exceeded his jurisdiction in disallowing the capital loss and determining the business loss by allowing set-off against capital gain-The order of the AO is set aside.[S. 45, 143(2)]

S. 115JB: Company-Book profit]-Method of accounting-Provision for loss of inventory-Diminution in value of asset-Any reduction in the value of inventory is to be added back to book profit computed in terms of s. 115JB(2)-Addition is affirmed. [S.115JB(2), 145]