S. 153B: Assessment-Search-Limitation-Extension of limitation period due to a reference made to foreign authorities under a tax treaty-Reference must be valid under the specific provisions of the relevant protocol-Following search in AMQ group, Assessing Officer made FT&TR reference seeking Hong Kong information for assessment year 2017-18, since India-Hong Kong DTAA effective 30-11-2018 permitted exchange only for subsequent fiscal years, such reference was impermissible and no limitation extension under Explanation (ix) to section 153B was available-DTAA-India-Hong Kong. [S. 147, 148,260A Art. 26]

S.153A: Assessment-Search-No actual search conducted-Survey converted to search without due process-Notices lacking reasons and unsupported by incriminating material-Notices quashed.[S. 132, 133A, 153B, Art. 226]

S. 151A: Faceless assessment of income escaping assessment-Reassessment-Jurisdictional Assessing Officer (JAO) as well as Faceless Assessing Officer (FAO) possess concurrent jurisdiction to initiate reassessment proceedings under section 148-Notice issued by JAO is valid and not in contravention of the statutory scheme under section 151A. [S. 147, 148 Art. 226]

S. 151: Reassessment-Sanction for issue of notice-Cash credits-Share capital and share premium received-Accommodation entries-Reopening of assessment-Approval under section 151-Single line approval recording satisfaction held valid-Competent Authority used language ‘Yes, I am convinced it is a fit case for reopening of assessment under section 147 by issuing notice under section 148’, same would satisfy the mandate of section 151-ITAT order quashing reassessment set aside low tax effect-Exception. [S. 68, 147, 148, 268A]

S. 149: Reassessment-Time limit for notice-Notice issued under section 148, pursuant to an order passed under section 148A(d), beyond the prescribed statutory period of 30 days was bad in law. [S. 148, 148A(b), 148A(d), TOLA S. 3, Art. 226]

S. 148: Reassessment-Reason to believe-Information/material indicating escapement of income-Purchase of flat from builder does not by itself bar reassessment-S. 148 as applicable from 1-4-2021 [Art. 226]

S. 147: Reassessment-Disallowance of expenditure-Exempt income-Assessee participated in proceedings and objections disposed of by a speaking order-Writ petition challenging notice under section 148 not maintainable at show-cause stage-Order of single judge set aside. [S.14A, 148, Art. 226]

S. 147: Reassessment-Reason to believe-Order of Transfer Pricing Officer for subsequent assessment year can be taken into account for reassessment of period prior to amendment of section 92-Writ petitions dismissed. [S. 92, Art.226]

S. 147: Reassessment-Reassessment order passed in reliance on a superior court ruling after original notices were quashed by the High Court-An unappealed High Court judgment quashing a notice remains final and cannot be bypassed via subsequent universal rulings. [S. 148, 148A(b), 148A(d), 149, Art. 226]

S. 144C: Reference to dispute resolution panel-Reference to TPO under section 92CA was made on 11-01-2022 after expiry of limitation for passing an assessment order under section 153(2) on 31-03-2021; it was without jurisdiction. The order passed under section 92CA (3) on 27-01-2022 and consequential proceedings under section 144C were set aside. [S. 92CA (3), 153(2), Art. 226]