S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Settlement Commission-Settlement of cases-Reassessment-Order passed by way of settlement of case is conclusive-Order cannot be reopened except in case of fraud or misrepresentation-Issues considered by Settlement Commission-Re assessment notice is not valid. [S. 147, 148,148A(b), 148A(d), 245D(4), 245D(6), 245D(7), 245H, 245I, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued on the ground of non filer of return of income-Return was filed and refund was granted-Notice and order is quashed. [S. 139, 143(1), 147, 148, 148A(b), 148A(d), 149, 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information from insight portal that assessee had transacted with Mutual Fund found to be involved in scam-No nexus between belief and material-Reassessment notice and order disposing the objection is quashed-Court can examine relevancy of recorded reasons in writ jurisdiction. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148: Reassessment-Notice-Limitation-Amendment in law-Effect of amendment with effect from 1-4-2021-Notices dated 31-3-2021, but dispatched on 1-4-2021 or thereafter from Income-Tax Business application portal-Notices barred by limitation. [S. 147, 148, 149, 151, Art. 226]

S. 147 : Reassessment Business expenditure-Incidental benefit to third party is not relevant-Notice and order disposing the objection. is quashed. [S.37(1), 148, Art.226]

S. 147 : Reassessment-Order is passed after giving a reasonable opportunity of hearing-No evidence that violation of principle of natural justice had caused prejudice to assessee-Writ is not maintainable. [S. 148, Art. 226]

S. 147 : Reassessment-Reassessment should be based on reasons given in notice-Reasons not found valid-No addition was made on the basis of recorded reasons-Additional grounds cannot validate reassessment-Alternate remedy is not an absolute bar on issue of writ.[S.45, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Transaction in shares-Live link between belief and material in possession is not established-Reopening on suspicion is impermissible. [S. 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Eligible assessee-Draft assessment order-Failing to communicate to Assessing Officer Final assessment order is passed during pendency of objections-Order set aside and Assessing Officer is directed to pass fresh order in accordance with directions of Dispute Resolution Panel. [S. 143(3) 144B, 144C(2), 144C(3), 144C(4), Art.226]

S. 144C : Reference to dispute resolution panel-Eligible Assessee-Draft assessment order-Final assessment order passed while assessee’s objections against draft assessment order sub-judice before Dispute Resolution Panel-Assessment order, notices of demand and penalty set aside-Assessing Officer is directed to pass fresh order in accordance with directions from Dispute Resolution Panel. [S. 144, 144B, 144C(2)(b)(ii), 144C(3), 156, 270A, 274, Art. 226]