S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Directions of Supreme Court in UOU v. Ashish Agarwal without following amended law-Bar of limitation-Dicta laid down by Supreme Court in UOI v. Rajeev Bansal-Notices and order barred by limitation.[S. 142(1), 147, 148, 148A(b), 148A(d), 226].

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless regime-Jurisdiction of JAO-Notice after three years-Sanction of Specified Authority-Approval to be obtained from Principal Chief Commissioner-Approval from Principal Commissioner-Sanction is invalid-Order and consequent notice is invalid S. 148. [S. 147, 148A(b) 148A(d) 151(i), 151(ii) 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Initial notice issued within limitation period-Subsequent order and notice for reopening assessment issued based on assessee’s reply to initial notice-Held, Notice not barred by limitation-Notice and reassessment proceedings valid. [S. 147, 148, 148A(b),148A(d), 149(1)(a), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Initial notice issued within limitation period-Subsequent order and notice for reopening assessment issued based on assessee’s reply to initial notice-Held, Notice not barred by limitation-Notice and reassessment proceedings valid-SLP of assessee dismissed. [S. 147, 148, 148A(b),148A(d), 149(1)(a), Art.126]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless regime-Jurisdiction of JAO-Notice after three years-Sanction of Specified Authority-Approval to be obtained from Principal Chief Commissioner-Approval from Principal Commissioner-Sanction is invalid-Order and consequent notice is invalid-SLP delayed by 248 days-SLP dismissed on account of delay as well as on merits. S. 147, 148A(b) 148A(d) 151(i), 151(ii) 151A, Art. 136]

S. 147 : Reassessment-With in four years-Change of opinion-Foreign exchange loss-Information relating to foreign currency transactions and loss was subject matter of query by Assessing Officer-Reassessment notice and order disposing the objection was set aside.[S. 37(1), 148, Art. 226]

S 147 :Reassessment-Strictures-Failure to produce reasons recorded and original assessment record-Record not traceable-Appeal dismissed-Cost of Rs.5000 levied on revenue [S. 148, 260A]

S. 147 : Reassessment-With in four years-Cash credits-Capital gains0 Book profit-Notice issued based on information in Insight Portal-Price manipulation in shares-Assessing Officer had no other specific information relating to assessee’s share transactions-Notice quashed.[S. 45, 68 115JB, 143(3), 147, 148, Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-Anonymous donations received in hundi-Donations received in form of ornaments not invested in prescribed form as mandated under section 11(5) of the Act-No new tangible material coming to possession of Assessing Officer after completion of scrutiny assessment-Notice and order rejecting assessee’s objections and subsequent proceedings quashed and set aside.[S.11(5), 12A, 13(1(d), 115BBC(1)(2)(b) 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Depreciation on goodwill and additional depreciation-No failure to disclose material facts-Slump sale-Depreciation-Suspicion-Disclosure before settlement commission-Third party disclosure-Notice and order disposing the objection was quashed.[2(42C), 32, 32AC, 148 Art. 226]