S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Investigation Wing-Unexplained moneys-Reassessment is valid where reopening is based on fresh tangible material received subsequently, and therefore does not amount to a change of opinion, even if the issue was examined in the original scrutiny assessment. [S.69A, 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information from Investigation Wing-At the section 148A stage, furnishing information suggesting escapement of income is sufficient; non-supply of the complete underlying material does not vitiate the notice. [S. 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order under section 148A (3) was passed on a ground not forming part of notice issued under section 148A (1)-Notice issued under section 148 pursuant to such order passed under section 148A (3) of the Act is bad in law. [S. 148, 148A(b), 148A(d),148A(3), Art . 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Dividend received from mutual funds-Reopening of assessment cannot be sustained when it is based solely on third-party survey findings, without any tangible material linking the assessee to the alleged sham transactions. [S. 10(35), 133A, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Purchase and sales-The assessee had dealt with information supplied to it by the revenue and had meticulously satisfied the data by comparing it with books of account-Reassessment notice and consequential orders were quashed. [S. 68, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Claim of depreciation disallowed in earlier year has been deleted in appeal proceedings by Appellate Tribunal-Reopening notice issued for subsequent assessment year to disallow the claim of depreciation in contravention of the order passed by Appellate Tribunal is against the settled provisions of law-Reassessment notice and consequential orders were quashed by High Court-SLP of revenue was dismissed on account of delay of 124 days as well as on merits. [S. 32, 32AC, 92BA,148 Art . 136]

S. 148: Reassessment-Notice-Limitation-Notice under section 148 issued on 23-4-2022 for assessment year 2015-16, being issued after 1-4-2021, was beyond limitation and without jurisdiction-Notice and consequential orders were quashed and set aside. [S. 144, 144B, 147, Art . 226]

S. 148 : Reassessment-Issue of notice-Unsigned notice-Notice neither manually nor digitally signed-Statutory mandate of section 282A violated-Defect not curable under section 292B or section 292BB-Notice and all consequential proceedings quashed. [S. 147, 156, 271(1)(c), 282A, 292B, 292BB, Art. 226]

S. 148: Reassessment-Notice-Jurisdiction-Reassessment proceedings initiated under section 148 without complying with the mandatory faceless assessment procedure under section 144B are invalid in law, and the notice as well as all consequential proceedings are liable to be quashed. SLP of revenue dismissed. [S. 144B, 147, Art. 136]

S.147: Reassessment-Income from house property-Interest-Lender’s certificate-Property was let out throughout the year-Audit objection-Annual value was determined under section 23(1)(b), restriction under proviso to section 24(b) did not apply-Absence of any fresh tangible material-Reassessment notice and order disposing the objection were quashed and set aside. [S. 22, 23(1)(b), 24(b), 148, Art . 226]