S. 179 : Private company-Liability of directors-Recovery of tax-Petition for stay of proclamation and sale of assessee’s property-Assessee not challenging order holding her jointly and severally liable with company, nor attachment order-Assessee not impleading company-None of foundational orders challenged-Assessee or company unwilling to pay taxes, though demands attained finality-No severe financial hardship pleaded-Balance of convenience not favouring grant of an unconditional stay-Direction to deposit 50 per cent. of demand within eight weeks as condition for stay.[Art. 226]

S. 158BC : Block assessment-Undisclosed income-Benami companies-High Court holding findings of fact if not perverse cannot be interfered with in appeal-SLP dismissed. [S. 132, 158BB, 260A, Art. 136]

S. 153: Assessment-Reassessment-Limitation-Assessment order uploaded on portal after expiry of limitation period-Order time-barred-Violation of natural justice-Notices issued to wrong email ID despite intimation of fresh email IDs-No effective opportunity of personal hearing-Assessment order passed under influence of superior officers and without independent application of mind-Order quashed as non est.
[S. 143(3), 142(1), 119, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Cash credits-Accommodation entries-No incriminating material found in search of non-searched persons-Statement under section 132(4) alone, without corroborative material, insufficient basis for addition-Assessment proceedings vitiated. [S. 132, 153A, 153C, 292B]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Jurisdiction lies with Faceless Assessment Officer or Jurisdictional Assessing Officer-Contrary views in precedents-Decision in Mark Studio India Pvt. Ltd. v. ITO1 dissented from Matter referred to Division or larger Bench.[S. 144B, 147, 148, 148A, 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Face less assessment-Mandatory-Notices and orders issued by jurisdictional Assessing Officer-Invalid–Notification No.18 of 2022 dated 29-3-20221. [S. 144B, 148, 148A(b) 148A(d), 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction of Income-tax authorities Faceless procedure-Mandatory-Notices and orders issued by jurisdictional Assessing Officer-Invalid [S. 144B, 148, 148A(b), 148A(d), 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice dated 31-3-2021 under section 148 was issued within extended limitation period under section 149(1)(b) as it stood till 31-3-2021-Notice is not time barred even after application of first proviso to section 149 as amended with effect from 1-4-2021. [S. 148, 148A(b) 148A(d), 149(1)(b), Art. 226]

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]