S.147: Reassessment-After the expiry of four years- Audit objection – Not accepted by the Assessing Officer –Borrowed satisfaction – No failure to disclose material facts – Notice is held to be bad in law [ S.148 , Art .226 ]

S.147: Reassessment-After the expiry of four years- Manufacture -Change of opinion- Based on the basis of commission issued – Held to be bad in law and impermissible. [ S .2(29BA) 131ID , 80IB ,148 , Central Excise Act, 1944 S.2(f) ]

S.147: Reassessment-After the expiry of four years- Primary facts disclosed — Assessing Officer not making appropriate calculation —Notice of reassessment issued without jurisdiction — Existence Of Alternate Remedy would not bar issue ow writ to quash notice [ S.14A , 148 Rule 8D ,Art , 226 ]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts – Merely because the Assessing Officer did not record such acceptance in the assessment order that would not be a ground to conclude that income had escaped assessment- Reassessment notice is held to be not Valid [ S. 36(1)(iii), 40(a)(ia), 148 ]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts – Reassessment order is held to be not valid. [ S.148 ]

S.147: Reassessment-After the expiry of four years- No new tangible material -Maintaining separate books of account – Notice is held to be bad in law [ S.80IA , 148 ]

S.147: Reassessment-After the expiry of four years- No new material -Change of opinion – Deemed income -Notice issued by same Assessing Officer who proposed to drop Audit objections on issue -Issue of notice is held to be not valid [ S. 2(22) (e ) 148 151 ]

S.147: Reassessment-After the expiry of four years- Mutual association – Interest from fixed deposits- A subsequent decision of the Supreme Court reversing the legal position existing at the time of passing of the assessment order could not be called an omission or failure on the part of the assessee to disclose fully and truly the material fact necessary for the relevant assessment- No failure to disclose material facts – Reassessment notice is held to be bad in law [ S. 4, 148 ]

S. 145 : Method of accounting – Completed contract method- Consistently followed and accepted by revenue —Method cannot be rejected .

S. 144C : Reference to dispute resolution panel -Draft assessment order — Limitation for filing objections – Draft assessment order served through Electronic mode on an earlier date but assessee opting for manual proceedings — Limitation to be calculated from date of receipt of draft assessment order manually. [ S.144C(2) Art , 226 ]