S. 151A : Face less assessment scheme-Reassessment-Faceless assessment-Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Invalid for lack of jurisdiction. [S.148, 148A(b), 148A(d), Art. 226]
S. 151A : Face less assessment scheme-Reassessment-Faceless assessment-Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Invalid for lack of jurisdiction. [S.148, 148A(b), 148A(d), Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Writ petition-Alternative remedy-Where appeal and revision proceedings were already pending against a reassessment order, writ petition challenging the said order on the ground of invalid sanction under section 151 was not to be entertained as the assessee had already availed of statutory remedies. [S 144, 144B, 147, 264, Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Writ petition-Alternate remedy-Where an assessee has already filed an appeal and a revision application against an assessment order, a writ petition challenging the same order on grounds of improper sanction is not maintainable. [S. 147, 264, Art. 226]
S. 151 : Reassessment-Sanction for issue of notice –Reopening after three years-Sanction from authority specified under Section 151(i) instead of Section 151(ii) is invalid. [S. 148, 148A(b), 148A(d),151(1), 151(ii), Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-For notice issued after three years from end of relevant assessment year, sanction is required under section 151(ii)-Sanction granted under section 151(i) renders notice invalid.[S. 148, 151(i), 151(ii), Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Jurisdiction-For a notice issued after three years from the end of the assessment year, sanction granted by the PCIT instead of the PCCIT is invalid. [S.148, 148A(b) 148A(d), 151(i), 151(ii), Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Reopening after three years-Approval by PCIT instead of PCCIT-Sanction held invalid. [S. 148, 148A(b), 148A(d), 151(ii), Art. 226]
S. 151: Reassessment-Sanction for issue of notice-For a notice issued after three years, sanction must be granted by the authority specified in section 151(ii); sanction under section 151(i) is invalid. [S. 147, 148, 148A, 151(1), 151(ii), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3]
S. 149: Reassessment-Time limit for notice-(AY. 2013-14)-Notice issued in July 2022 pursuant to Supreme Court decision in Ashish Agarwal is barred by limitation as the time limit under the unamended Act, including extensions under TOLA, had expired on 31.03.2021. [S. 147, 148, 148A, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3]
S. 149 : Reassessment-Time limit for notice-Notice for AY 2014-15 issued on 25.07.2022-Time limit under pre-amended law having expired on 31.03.2021-Notice held time-barred and quashed in view of first proviso to substituted Section 149. [S. 148, 148A(b),148A(d), Art. 226]