S. 153: Assessment-Limitation-Transfer pricing adjustments-Tribunal’s order remitting matter to Assessing Officer dated 21-10-2020 (after 01-04-2019)-Limitation period of twelve months expired on 21-10-2021-Assessment is barred by limitation. [S. 92CA, 153(3); Art. 226]

S. 153 : Assessment-Limitation-Limitation to be computed from date order is received from higher authority-Order received on 30-1-2021; order of assessment on 13-2-2023 barred by limitation. [S. 92CA, 153(3), Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Non application of mind-Notice and order disposing the objection was quashed. [S. 147, 148,148A(b), 148A(d), Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Satisfied-The approval is a safeguard and has to be meaningful and not merely ritualistic or formal-General order of approval for all the 111 cases-Mechanical according of sanction-Not valid.[S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice –Recording of satisfaction-Sanction was valid.[S. 148, Art. 136]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Original notice under section 148 issued before 1-4-2021 culminated in reassessment order attaining finality-Fresh notice under section 148A(b) impermissible-Supreme Court directions in UOI v. Ashish Agarwal limited to pending reassessment proceedings-Notice and order quashed. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry; providing opportunity before issue of notice-Faceless assessment-Initial notice and order-Pending appeal before Commissioner (Appeals) and revision application before Principal Chief Commissioner-Stay of assessment order until outcome of appellate proceedings and revisional application-All contentions of assessee kept open for raising before statutory authorities. [S. 144, 144B, 147, 148, 148A(b), 148A(d), 250, 253; Art. 226]

S. 148A: Reassessment-Conducting inquiry; providing opportunity before issue of notice-Recovery of tax-Insolvency of assessee-Effect of Insolvency and Bankruptcy Code, 2016-Claims of tax cannot be made subsequent to plan by Resolution Professional-All claims not forming part of resolution plan stand extinguished. [S. 144, 147, 148, 148A(b), 148A(d), Insolvency and Bankruptcy Code, 2016, S. 31(1), 238; Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Original notice under section 148 issued before 1-4-2021 which culminated in reassessment order attaining finality-Fresh notice under section 148A(b) issued pursuant to direction of Supreme Court in UOI v. Ashish Agarwal (2022) 444 ITR1 (SC), Supreme Court directions limited to pending reassessment proceedings-Notice and order quashed Fresh reassessment impermissible for concluded assessment [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Alternative remedy-Writ petition was dismissed. [S. 147, 147, 148A(b), 148A(d), Art. 226]