S. 153C: Assessment-Income of any other person-Search-No incriminating material was found-SLP of revenue dismissed.[Art. 136]

S. 153C: Assessment-Income of any other person-Search-Incriminating material belonging to or relating to a person other than the searched person is found during search proceedings-AO is required to proceed under section 153C and not under section 148-SLP of the revenue dismissed on account of delay of 56 days and also on merits. [S. 148, Art, 136]

S. 151 : Sanction for issue of notice-Reassessment proceedings are initiated beyond three years from the end of the relevant assessment year; prior sanction must be obtained from the specified authority under section 151(ii); sanction by any other authority is without jurisdiction and renders the reassessment proceedings invalid; SLP of the Revenue dismissed. [S. 147, 148, 148A(b), 151(ii), Art. 136]

S. 149: Reassessment-Time limit for notice-Period of limitation-Issuance of notice under section 148 within the limitation period is sufficient; inadvertent attachment errors or delayed viewing of the e-mail are curable defects and do not invalidate reassessment. [S. 147, 148, Art. 226]

S. 149: Reassessment-Time limit for notice-Notice under section 148 issued beyond the period of 6 years from the end of the relevant assessment year 2014-15 is barred by limitation-SLP of the revenue dismissed.[S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Notice under section 148 issued beyond the period of limitation prescribed under the first proviso to section 149(1) of the Act is barred by limitation and liable to be quashed-SLP of revenue delayed by 320 days-SLP dismissed on account of delay. [S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Notice dated 31.08.2024 issued under section 148 is beyond the period of six years from the end of Assessment Year 2016-17; therefore, the same is time-barred; SLP dismissed on account of delay of 309 days and also on merits. [S. 148, Art, 136]

S. 149: Reassessment-Time limit for notice-The statutory six-year period for reopening expired on 31-03-2021; a notice issued under section 148 on 30-08-2024 was barred by limitation and therefore without jurisdiction; SLP of the revenue dismissed on account of delay of 327 days and also on merits. [S. 147, 148A, Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Audit objection-Review/change of opinion on the same material, which is impermissible-Notice and consequential orders were set aside-Notice issued under section 148 on 31-3-2023 was beyond four-year limitation under first proviso to section 149 as applicable, so extended six-year period did not apply, rendering such notice and subsequent proceedings invalid and liable to be quashed. [S. 147, 148, 148A(b), 148A(d),149, Art . 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Investigation Wing-Unexplained moneys-Reassessment is valid where reopening is based on fresh tangible material received subsequently, and therefore does not amount to a change of opinion, even if the issue was examined in the original scrutiny assessment. [S.69A, 147, 148, 148A(b), 148A(d), Art. 226]