S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is quashed. [S. 148]

S. 144C : Reference to dispute resolution panel-Limitation-Legal issue-Can be raised at any time-Matter remanded to Assessing Officer to consider additional ground of limitation on Dispute Resolution Panel’s Direction. [S. 92CA, 153, 254(1), ITATR.11]

S. 144 : Best judgment assessment-Rejection of books of account-Estimate of gross profit-No purchases from shell companies-Declared greater profit from earlier years-No addition is warranted.

S. 153A : Assessment-Search-Information in Annual Information return is not incriminating material-Addition is deleted.[S. 5, 50C, 132]

S. 148 : Reassessment-Notice-Amalgamation-Factum of amalgamation intimated to Assessing Officer with request to cancel Permanent Account Number of amalgamating company-Notice in name of non-existent entity-Not sustainable.[S. 147]

S. 147 : Reassessment-Reasons recorded-Factual misstatements and inaccuracies-Sanction of commissioner without proper application of mind-Dispute Resolution Panel-Admitting errors-Reassessment is bad in law.[S.144C, 148, 151]

S. 147 : Reassessment-Settlement Of Case-Settlement Commission passing order settling case-Binding on department-Assessing Officer has no power to reopen assessment for year forming part of Settlement-Recovery of tax-Companies-Insolvency resolution-Resolution plan as approved by committee of creditors approved by National Company Law Tribunal-Binding on all Parties-Dues not forming part of resolution plan stand extinguished-Department has no power to reopen assessment [S.148, 245C(1), 245D(4)]

S. 147 : Reassessment-Reasons recorded-No addition is made on the basis of recorded reasons-Addition is made on other grounds which are not part of the recorded reasons-Reassessment is quashed.[S. 148]

S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Contrary to facts-All information was available while passing the original assessment order-Approval without application of mind-Reassessment is bad in law. [S. 132, 133A, 148, 151, 153A, 153C]

S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Reassessment is not valid-Approval is not valid [S. 132, 133A,148, 151, 153A, 153C]