S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Standard Operating Procedure (SOP)-Time allowed for reply to notice under section 148A(b) was 4 days instead of 7 days as per the Standard Operating Procedure (SOP) issued by the CBDT-No prejudice caused to the assessee merely because 4 days were provided instead of 7 days as suggested in SOP-Writ petition dismissed. [S. 148, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-A reassessment notice that was already time-barred before 1-4-2021 under the erstwhile law cannot be revived by applying Sec. 149(1)(b) (w.e.f. 1-4-2021)-Reassessment proceedings (including those routed through Ashish Agarwal judgement) would still be beyond limitation-the Revenue’s SLP was dismissed for delay.[S. 148, 148A(b), 148A(d), 149, TOLA, 2020, S. 3 Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Satisfaction of Assessing Officer at notice stage is sufficient for reopening-SLP assessee dismissed. [S. 147, 148A (b), 148A (d), Art. 136]

S. 148 : Reassessment-Notice-Cash credits-Notice must be issued by the Faceless Assessing Officer (FAO) and not by the Jurisdictional Assessing Officer (JAO)-Notice issued by JAO is a fatal defect and quashed.[S. 147, Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-Depreciation-Survey-Examined during the original assessment proceedings-Reassessment not valid-Omission to pass a speaking order on receipt of objections cannot be considered as fatal.[S. 133A,143(3), 148, Art. 226]

S. 147 : Reassessment-With in four years-Deemed Dividend-Trade Advances-Credit Balances-Common Shareholding-Reassessment Invalid. [S.2(22)(e), 148, Art. 226]

S. 147 : Reassessment-With in four years-Interest on borrowed capital-Change of opinion-Full disclosure during original assessment-Reopening held invalid.[S.36(1)(iii), 147, Art. 226]

S. 147: Reassessment-After the expiry of four years-Alleged bogus purchases-Unexplained expenditure-Full disclosure-Reason to suspect-Order of Tribunal quashing the reassessment order was affirmed. [S.69C, 148, 260A]

S. 147 : Reassessment-After the expiry of four years-Non-compete Fee-Revenue expenditure-Change of opinion-Full disclosure of facts-Reassessment notice and order disposing the objection was quashed.[S. 37(1), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Educational Society-Accumulation of income-Reassessment notice and order disposing the objection was quashed and set aside. [S. 11 (2), 14 Art. 226]