S. 153C : Assessment-Income of any other person-Search-Time limit for initiation of proceedings-Legal grounds-Notice was issued on 11-1-2016-Six years for which proceeding under section 153C could have been initiated were assessment years 2015-16 to 2010-11-Assessing Officer had no jurisdiction to initiate proceeding under section 153C for assessment year 2008-09-Lack of jurisdiction-Assessment order is quashed.[S.132, 254(1), ITAT, Rule 27]

S. 149 : Reassessment-Time limit for notice-Notice issued on 29-7-2022 for assessment year 2015-16-Last date for issuing notice under old provision was 31-3-2022,-Notice is barred by limitation.[S. 147, 148]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained Moneys-Non-Resident-Erroneous facts-Reassessment order is quashed.[S.69A, 148, 148A(b)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sanction-Income escaped less than Rs. 50 lakhs-Notice issued after three years-Income from other sources-Notice is void ab-initio. [S. 56(2)(vii)(b), 148, 148A(b), 148A(d), 149, 151]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Initiated as per the decision of UOI v. Ashish Agarwal (2022) 286 Taxman 183/ 444 ITR 1 (SC)-Assessing Officer treated initial section 148 notice as section 148A(b) notice as per Supreme Court decision-Reassessment order was passed without issuing fresh section 148 notice-Order is without jurisdiction and void ab initio. [S. 147, 148, 148A(b), 148A(d)]

S. 147: Reassessment-After the expiry of four years-Cash credits-Cash deposited in to bank-AIR information-Non application of mind by the Assessing Officer-Reasons recorded by Assessing Officer for reopening assessment were based on factual errors, reopening notice was void ab initio. Reassessment order is quashed. [S. 68, 143(3), 148]

S. 145 : Method of accounting-Whole sale food items-Estimation of net profit-Matter is remanded back to Assessing Officer to adjudicate afresh.

S. 143(1) : Assessment-Intimation-Prima facie adjustment-Excise duty-Adjustment made by Assessing Officer under section 143(1) by including excise duty in turnover is not sustainable.[S.143(1)(a), 145A]

S. 115-O : Domestic companies-Tax on distributed profits-Income-Deemed to accrue or arise in India-Dividend-DTAA does not get triggered when a domestic company pays DDT under section 115-O-Order of the AO rejecting the claim of refund of excess DDT is affirmed.-DTAA-India-Italy [S.9(1)(iv), Art. 11]

S. 115BAC : Tax on income of individuals and Hindu Undivided Family-Old scheme-New tax scheme and filed form 10-IE while filing revised return, requirement of filing Form 10-IE was directory in nature and not mandatory and it was sufficient compliance if said form was before Assessing Officer at time of assessment.[S.139(1), 143(1) R. 21AG(1), Form No 10-IE]