S. 151A : Faceless assessment of income escaping assessment- Reassessment-Notice-Jurisdiction-Scheme-Procedure adopted by Department in contravention of statutorily prescribed procedure-Office Memorandum cannot override mandatory specifications in scheme-Reassessment notice is set aside-Department given liberty to proceed in accordance with amended provisions. [S. 144B, 147, 148, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Amendment of Section 151 with effect from 1-4-2021-Issue of notice in respect Of Assessment years 2016-17 and 2017-18 notice is not valid-Interpretation of taxing statutes-Proviso. [S. 147, 148,149(1), 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Bar Of Limitation-Initiation of proceedings from 1-4-2021-Notice issued beyond period of limitation of six years-Notice and order is quashed and set aside. [147, 148, 148A(d), 149, Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sanction for notice issued by Income-Tax Authority which did not have jurisdiction-Notice is not Valid.[S. 147, 148, 151, Art.226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Time granted to respond to notice lesser than prescribed seven days-Opportunity of personal hearing not granted-Notices and order set aside. [S. 147, 148, 148A(b). 148A(d),151A Art. 226]

S. 147 : Reassessment-Non-Resident-Permanent Establishment-Transactions found to be at arm’s length-Supplying materials through direct imports to Indian Railways-Allegation of wholly owned subsidiary-No material to prove conclusively that Indian Subsidiary’s place assessee’s Permanent Establishment falling in any of three Categories. Petition is allowed. Liberty is given to Department to independently examine whether Delhi Office of assessee a Permanent Establishment or service Permanent Establishment-DTAA-India-USA. [S.92CA, 133A, 148, Art.5(1), 5(2), 5(3), 5(4)]

S. 147 : Reassessment-Effect of third proviso to Section 147-Income which was the subject matter of appeal-Notice Of Reassessment In Respect Of Such Income Not Valid. [S.80IB(10), 148, 250, Art. 226]

S. 147 : Reassessment-Financial cost-Interest-Tax deducted at source-Query was raised in the course of original assessment proceedings-Reassessment notice on same issue is not valid.[S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Capital gains-Sale consideration-Division of income between spouses and not assets for capital gains-Portuguese Civil Code-Notice based on wrong facts and erroneous reasons-Notice and order disposing the objection is quashed. [S.5A, 50C, 133A, 148, Art. 226]

S. 145 : Method of accounting-Survey-Excess-stock-Surrender-Reflected in sales and closing stock-Accounting treatment is held to be proper-Investment in excess stocks to be taxed as part of business income and not as income from other sources. Proper-Accrual-Notional interest-Lower interest charged from wife of one of partners-Commercial expediency-Notional addition is not justified-Partners were paid interest at 12 Per Cent. and balance in partners’ account much more than amount advanced to wife of partner-Disallowance is to be restricted at 2 Per Cent.[S. 4, 5,,28(i), 69, 133A]