S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Assessee had not initiated any legal proceedings to assail the notice dated 30.06.2021 issued under section 148-Subsequent notice issued under section 148A(b) pursuant to decision of Hon’ble Supreme Court in UOI v Ashish Agarwal (2022) 286 Taxman 183/ 444 ITR 1 (SC) is barred by limitation. [S. 148, 148A(b) 148A(d) 149, Art. 226]

S. 148A: Conducting inquiry, providing opportunity before issue of notice under section 148-decision of Hon’ble Supreme Court in the case of UOI v. Ashish Agarwal [2022] 444 ITR 1 (SC) does not mandate reopening of completed assessment.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Before passing order under S. 148A(d) the Officer ought to give a personal hearing if requested for by the assessee-Grant of approval by PCIT without application of mind to the form of approval-Order and notice liable to be set aside. [S. 148, 148A(b), 148A(d),149(1)(b), 151 Art. 226].

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by JAO in defiance of section 144B is bad in law. [S. 144B(7), 144B(8)_, 148, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Non-resident-Term deposits out of remittances from Dubai-Assessing Officer Vijayanagram had jurisdiction over assessee, notice issued by Assessing Officer, Vapi is in valid-Reassessment notice and order disposing the objection is quashed.[S.10(4)(ii), 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Face less assessment-Central charge-International taxation charges-Faceless mechanism would also be applicable to cases of Central Charges and International Taxation charges-Notice issued by JAO is bad in law. [S.144B(2) 148, 151A]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Search and seizure-Notice for reopening u/s 148 issued by the Jurisdictional Assessing Officer (JAO)-Scheme of Faceless Assessment framed vide Notification dt. 29–03–2022-Not applied to cases of search and seizure u/s 132-Challenge of notice u/s 148 on the ground that it could have been issued only through automated allocation in faceless manner and not by JAO-Writ petition is dismissed.[S. 132, 148, 148A(b), 148A(d),151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Reassessment was concluded on 26-3-2002-Reassessment proceedings on same set of facts is not sustainable.[S. 147, 148, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Dead person-AO issued notice in the name of deceased assessee in spite of being informed by the petitioner (son of the deceased assessee) to the AO –Notice and subsequent order is quashed and set aside. [S. 148, 148A(b), 148A(d), 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Given only two working days to comply the notice-Notice and order is quashed and set aside. [S.148, 148A(b), 148A(d), Art. 226]