S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notices issued on or after 1-4-2021 relating to assessment years 2013-14 and 2014-15, under section 148 (old)-Treating the same as under newly inserted section 148A by Finance Act, 2021 which came into effect from 1-4-2021-Notice and all subsequent proceedings on the basis of said notices are not sustainable in law being barred by limitation as provisions of TOLA applied to pre-amended law as applicable till 31-3-2021. [S. 148, 148A(b), 148A(d), 149, Art. 226, Taxation and Other Laws (Relaxation and Amendment of certain Provisions) Act, 2020]

S. 148 : Reassessment-Notice-Dead person-Notice issued to a dead person to reopen the assessment is null and void. [S. 147, Art. 226]

S. 147 : Reassessment-With in four years-No new tangible material-Review of the assessment to rectify earlier error or omission-Notice and order disposing the objection is quashed. [S. 148, 263, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Accommodation entry-Information supplied by Investigation Wing-Bogus sales, purchases, fictitious loans etc-Notice and order disposing the objection is quashed. [S.68, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Depreciation-Subject matter of appeal-Third proviso-Reassessment notice and order disposing the objection is quashed. [S. 11,32, 148, Art, 226]

S. 143(3): Assessment-Losses under head capital gains-Pendency of appeal-Alternative remedy-Writ is not maintainable. [S. 45, 74, 246A, Art. 226]

S. 143(3):Assessment-Reassessment-Death of assesseee-Legal representative-Defective appeal-Legal representatives must register themselves in the IT Portal by submitting the PAN of the deceased assessee along with their PAN as the legal representative of deceased assessee and produce a death certificate-Writ petition is dismissed.[S. 148, 148A(b), 148A(d), 159, 221(1) 246A, Art. 226]

S. 132(3) : Search and seizure-Prohibitory order-Article-Liquor-Contention of Revenue that liquor cannot be included in the expression of valuable article is rejected-Order issued under section 132(3) is quashed on the ground that Revenue could have invoked section 132(1) of the Act. [S. 132, Art. 226]

S. 119 : Central Board of Direct Taxes-Return-Condonation of delay-Filed after six years-Directed to accept the return and the assessee is directed to rectify the errors and the claim for refund should be processed in accordance with law. [S. 119(2)(b), 139, 240, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Most appropriate method-TNMM-CUP-Most appropriate method-Order of the Tribunal is affirmed-No substantial question of law.[S. 260A]