S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice after six years Limitation-Order passed under section 148A(d) and consequent notice dated 1-5-2024 issued under section 148 after expiry of limitation period of six years on 31-3-2024-Barred by limitation-Faceless assessment-Faceless Assessment Officer has exclusive jurisdiction to issue notice-Notices issued and order passed by Jurisdictional Assessing Officer in contravention of provision invalid-Notice and order set aside.[S. 80-IA, 147, 148, 148A(b),148A(d), Art.226]

S.147: Reassessment-After the expiry of four years-No new material-Change of opinion-Lease back-Notice and consequential proceedings quashed and set aside.[S. 143(1), 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Non eligible assessee-Assessing Officer cannot pass draft assessment order under section 144C(1)-Draft assessment order, final assessment order and notices of demand and penalty set aside. [S. 92CA(3), 143(3), 144C(15), 156, 270A, 271AAC, Art. 226]

S. 143(3): Assessment-Assessment order passed in disregard of principles of natural justice and to be quashed-Strictures-Direction to CBDT –False affidavit by the Revenue before High Court-Assessment order quashed-CBDT is directed to take appropriate action. [S.11, 12, 12A(b) R. 17B, Form No. 10B Art. 226]

S. 143(3): Assessment-Return of income-Revised return of income filed within time-Once revised return filed, original return stands obliterated-Assessment order set aside-Order of Commissioner (Appeals) modified and matter remitted to Assessing Officer. Assessing Officer directed to determine taxable income on the basis of revised return [S.139(1), 139(5), 143(2)]

S. 132B: Application of seized or requisitioned assets-Cash seized-Assessees applying within thirty days of seizure of cash explaining source-No order passed with regard to liability or return Proviso would not come into play-No time line prescribed for recording of satisfaction by Assessing Officer-Release cannot be ordered However, since assessees had informed authorities about cash in bank locker even before recovery thereof, authorities directed to decide assessees’ application within four weeks.[Art. 226]

S. 119: Central Board of Direct Taxes-Circular-Delay of eight days in filing audit report-Technical glitch-Commissioner’s order rejecting condonation application set aside-Commissioner directed to consider audit report and grant all consequential reliefs. [S. 12A, 119(2)(b), R.17B, Form 10B, Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Dealy in filing audit report-Delay of 76 days-Reasonable cause-Genuine hardship-Force majeure-Circular extending period of limitation-Order of Commissioner rejection of application set aside-Matter remanded to the Commissioner for fresh consideration.[S.12A, 119(2)(b), 139, 143(1), Art. 226, R. 17B, Form 10B]

S. 115JA: Company-Book profit-Voluntary retirement scheme-Advertisement expenditure-Order of Tribunal allowing the claim is affirmed. [S.260A]

S. 80IB(10): Housing projects-undertaking-Joint venture development agreement with landowners-Failure to produce document-Interpretation of taxing statutes–Exemptions–Strict construction-Order of Tribunal set aside. [S.260A]