S. 147: Reassessment-Formation of belief by Assessing Officer-The Assessing Officer acted on directions of superiors without forming an independent belief that income had escaped assessment; as mandated under section 147, reassessment was invalid.[S. 92C, 148, 260A]

S.147: Reassessment-Faceless assessment-Objections to reopening-Mechanical disposal of objections-Matter remanded.[S. 144B, 148, Art. 226]

S. 147: Reassessment-Claim was pending in appeal-Claim for deduction under section 10B was pending before the Commissioner (Appeals); reopening proceedings initiated in respect of matters connected with such assessment were not sustainable in view of the third proviso to section 147. [S.10B, 148, 246A, Art. 226]

S.147: Reassessment-After the expiry of four years-Reasons recorded for reopening-Vague reasons relating to alleged unexplained credits, and the Assessing Officer subsequently sought to improve or supplement reasons while disposing of the assessee’s objections-Recorded reasons did not allege any failure on the part of the assessee to disclose material facts-Reopening notice and order rejecting objections were quashed and set aside.[S.68, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Cash sales-Unexplained money-Income already assessed substantively in another year-Reassessment notice and order disposing of the objection were quashed and set aside.[S. 69A, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Change of opinion-Reopening notice was held to be invalid and was quashed.[S. 40(a)(ia), 80P, 148 Art. 226]

S. 147: Reassessment-After the expiry of four years-Tangible material-Information regarding undisclosed funds routed through tax-haven companies-Reopening valid.[S. 69A, Art. 226]

S.147: Reassessment-After the expiry of four years-Expenditure incurred on gift articles-No failure to disclose material facts-Reopening quashed.[S. 37(1), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Subsequent tax residency certificate-Reopening invalid.[S. 6, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment quashed.[S. 36(1)(vii), 148, Art. 226]