S. 153C : Assessment-Income of any other person-Search-Recording of satisfaction-Copy in verbatim of satisfaction note of Assessing Officer of searched person-No jurisdictional error-Recording of satisfaction is valid. [S. 132, Art.226]

S. 153A: Assessment-Search-No incriminating materials were found-Addition cannot be in respect of completed or Unabated assessment.[s. 55, 68 69C 132]

S. 153A : Assessment-Search-Long term capital gains-No incriminating material is found during search-Order of Tribunal deleting the addition is affirmed.[S. 58,68, 69C, 260A]

S. 153A : Assessment-Search-Cash credits-Incriminating document-Document of shareholding pattern document prepared by way of secretarial compliance report, which was filed along with company’s annual return in Form MGT-7 with ROC-Available in public domain-Would not constitute incriminating document to justify reopening of assessment of unabated/completed-No substantial question of law. [S. 132, 260A]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Cryptic notice-Information-Order was passed without considering the objections filed by the assessee-The order violative of the mandatory requirements of section 148A-The assumption of jurisdiction under section 147 was perverse and unsustainable-On the facts the matter did not warrant remand-The orders under section 148A(d) and the notices issued under section 148 were quashed and set aside. [S.2(42A) 47(vid), 56(2)(x)(c), 147, 148, 148A(b), 148A(d), Art. 14, 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice mentioning for which the notice issued-Transactions recorded of other financial year-Notice valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accommodation entries alleged Mr. Rakesh Garg-No dealings with alleged accommodation entry provider-Reassessment notice issued earlier was dropped-Issue of notice under amended provision on same issue is not valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Charitable or religious trust-Registration procedure-Alternative remedy-Writ petition is dismissed. [S. 12AA, 148A(b), 148A(d),164, 246A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice issued after six years-Limitation period expired on 31-3 2020-Limitation for reopening assessment for assessment year 2013-14 expired on 31-3-2020, notice issued in June 2021 in case of assessee was barred by limitation, hence, section 148 notice dated 28-7-2022 issued pursuant to UOI v. Ashish Agarwal(2022) 286 Taxman 183/ 444 ITR 1 (SC) is quashed and set aside as it was invalid, without jurisdiction and barred by limitation [S. 148, 148A(b),148A(d), 149, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notices issued u/s 148 on or after 1-4-2021 relating to assessment years 2013-14 and 2014-15-Time limit-Finance Act, 2021 which came in to effect from 1-4-2021-TOLA applied to pre-amended law as applicable till 31-3-2021-Notices and all subsequent proceedings are quashed-Interpretation of taxing statutes-Legislative intent.[S. 147, 148, Art. 226]