S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Pendency of appeal-Appellate authority bound by earlier decision of High Court-Stay of assessment orders until outcome of appellate proceedings-All contentions kept open. [S.144B, 147, 148, 148A(b), 148A(d), 246A, 250, Art. 226]

S. 147 : Reassessment-Survey-Unexplained investments-Departmental Valuation Officer showing significant difference between declared costs and actual construction value-Tangible material-Reassessment valid. [S. 131, 133A, 142(1), 143(2), 148, Art. 226]

S. 147 : Reassessment-Capital gains-Gift of shares
Gift of shares without consideration not liable to capital gains-Notice of reassessment invalid. [S. 45, 47(iii), 50CA, 50D, 143(1), 148, Art. 226]

S. 147 : Reassessment-Change of opinion-No new tangible material-Reassessment notice and order disposing the objection. was quashed-Existence of alternate remedy-Not an absolute bar on issue of writ.[S. 148, Art.226]

S. 147 : Reassessment-After the expiry of four years-Failed to electronically upload Form 10CCB along with return of income within the timeframe prescribed under section 139-Reassessment notice and order disposing the objection were quashed and set aside. [S. 80IA(7), 139, 148, Form 10CCB, R.12, Art. 226]

S. 145 : Method of accounting-Solicitor-Client’s money-Amounts received by solicitor from clients for specific tasks-Amounts received in fiduciary capacity-Not assessable as income. [S.4, 260A]

S. 144B : Faceless Assessment-Subsequent notice indicating the Department’s intention to make assessment in a faceless manner and requiring the assessee to file a reply on the online portal rather than to the jurisdictional AO-Notice need not be interfered with. [S. 147, 148, 151(1), Art. 226]

S. 143(3) : Assessment-Jurisdiction to assess-Formation of Centralised Processing Centre-CPC acts as facilitator and does not take away jurisdiction of Assessing Officer under section 120. [S. 120, 143(1A), 154, 263, 264, Art. 226]

S. 143(3): Assessment-Pendency of appeal-Writ-Alternative remedy-Suppressing material information of filing of statutory appeal-Pursuing parallel remedies amounted to treating extraordinary remedy as an alternate remedy to appellate remedy-Petition dismissed and cost of Rs. 1 lakh was imposed to be paid to the High Court Employees Medical Welfare Fund at Mumbai. [S. 246A, Art, 226]

S. 132 : Search and seizure –Stock in trade-Burden of proving goods constituted stock-in-trade of business, lies on assessee.[S. 131(IA), 132(1)(iii),132(4) Art. 226]