S. 147 : Reassessment – After the expiry of four years – Unexplained moneys – No return is filed within time allowed – Not explained receipt of amount – Reassessment notice is held to be valid – Writ petition is dismissed. [ S.69A, 148 , Art. 226 ]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sale of immovable property-Failure to reply-Reasonable cause-In view of submissions made by assessee, assessment order and penalty order is set aside on condition that assessee would remit a sum towards income tax demand, as agreed to, and submit a reply to show cause notice-Matter remanded- Petitioner is directed to deposit Rs .2,00,000 lakhs towards income -tax demand . [S. 143(3), 148, 148A(b) 148A(d),Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Power to transfer cases-Transfer order dated 11-1-2023-Case of petitioner was transferred from Vadodara to Ahmedabad-Assessing Officer at Vadodara had no jurisdiction to issue notice under section 148A for re-opening of assessment is not valid-Once NCLT approved application filed under IBC, 2016 and resolution plan was also approved, Assessing Officer would not have any jurisdiction to re-open assessment with regard to assessment year 2019-20 [S. 127(2), 127(3), 148, 148A(b) 148A(d), Insolvency and Bankruptcy Code, 2016, 10, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Investigation was shared to the petitioner-Sufficient time was allowed to file the reply-Sanction was granted-Notice is valid-Writ petition is dismissed.[S. 148, 148A(b) 148A(d) 151(2), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Opportunity of hearing-Order passed without giving an opportunity of hearing is quashed and set aside.[S. 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notices issued by Jurisdictional Assessing Officer (JAO)-Re-assessment proceedings initiated without conducting faceless assessment as envisaged under section 144B-Contrary to provision of law-Notice and order is quashed.[S.119,120, 144B(7), 144B(8), 148, 1488A(b), 148A(d)),151A(2), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notices issued by Jurisdictional Assessing Officer (JAO)-Re-assessment proceedings initiated without conducting faceless assessment as envisaged under section 144B-Contrary to provision of law-Notice and order is quashed.[S.119,120, 144B(7), 144B(8), 148, 1488A(b), 148A(d)),151A(2), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notices issued by Jurisdictional Assessing Officer (JAO)-Re-assessment proceedings initiated without conducting faceless assessment as envisaged under section 144B-Contrary to provision of law-Notice and order is quashed.[S.119,120, 144B(7), 144B(8), 148, 1488A(b), 148A(d)),151A(2), Art.226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notices issued by Jurisdictional Assessing Officer (JAO)-Re-assessment proceedings initiated without conducting faceless assessment as envisaged under section 144B-Contrary to provision of law-Notice and order is quashed.[S.119,120, 144B(7), 144B(8), 148, 1488A(b), 148A(d)),151A(2), Art.226]

S. 143(3) :Assessment – Reassessment – Notice – Principle of natural justice – Alterative remedy – Non – existent company – Assessment order is up loaded – Cash deposits – Notices were served on assessee’s Chartered Accountant through e-mail Id which is registered by assessee with Income-tax Department – Writ petition is dismissed – Liberty is granted to assessee to appeal against assessment order made in pursuance of impugned notices on all grounds . [ S. 147, 148 , Art . 226 ]