S. 151: Reassessment-Sanction for issue of notice-Limitation-Information-Mere generation of notice on the ITBA screen cannot in fact or in law constitute issue of notice-Cash deposit-The AO has failed to establish with concrete information that there is escapement of income-Notice was issued after obtaining the approval from Jt. CIT and not with the approval of the prescribed authority-Reassessment notice and consequential order are quashed. [S. 147, 148, 148A(b)]

S. 151: Reassessment-Sanction for issue of notice-Specified authority-Sanction form Principal CIT and not Chief CIT-Reopening proceedings and the reassessment order passed are quashed.[S. 151(ii)]

S. 149: Reassessment-Time limit for notice-Notice issued after expiry of six years from the end of relevant assessment year-Notice for asst. yr. 2015-16 issued on 15th July, 2022 under s. 148 is barred by limitation, hence bad in law [S. 148]

S. 149: Reassessment-Time limit for notice-Cash deposit-The AO assumed jurisdiction by passing an order under s. 148A(d) on the basis of incorrect information-Notice beyond three years from the end of the relevant assessment year-The notice issued by the AO under S. 148 dt. 28th April, 2022, is illegal, void ab initio and consequently, the assessment order passed was quashed. [S. 143(3), 147, 148, 148A(b), 148A(d)]

S. 147 : Reassessment-Search-Loose papers-Satisfaction-The Assessing Officer ought to have initiated action under section 153C-Reassessment was quashed and set aside. [S. 132, 148, 153C]

S. 147: Reassessment-Reason to believe-Information received from Dy. CIT(E)-No live link or rational belief in the reasons recorded-AO should not act on the dictate of any other authority like Dy. CIT(E)-Reassessment was quashed. [S. 11, 13(1)(a), 148]

S. 147: Reassessment-Information from Investigation-Wing-No tangible material-No application of mind-Reassessment notice and consequential order were quashed as illegal.[S.143(3) 148]

S. 147: Reassessment-No failure to disclose material facts-Notices issued under S. 148 under the new regime for the relevant asst. yrs. 2014-15 and 2016-17 on 25th July, 2022 and 26th July, 2022, respectively, were barred by limitation-Reassessment proceedings are quashed.[S. 148, 148A(b)]

S. 145: Method of accounting-Rejection of books of account-Estimation of gross profit-No comparative cases-GP declared was more than earlier years-Addition was deleted-ERP software expenses as revenue expenditure cannot be accepted-Purchase invoices were produced before the Assessing Officer-No violation of R.46A [S.37 (1), 145(3) 251, R.46A]

S. 145: Method of accounting-Builder and developer-Project completion method-Advances received by the assessee from the customers cannot be taxed in this year when the same have been adjusted in the sales in the assessment year 2018-19