S. 153C: Assessment-Search-Other person-Date of initiation of search-Date of handing over seized material-Since initiation of search was subsequent to 1-4-2021, provisions of section 153C would not apply and thus, impugned notice issued under section 153C was to be quashed-Notice invalid. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Assessing Officer of searched party and third party was the same-Time limit of clause (ii) of third proviso to section 153B(1) shall apply which was 12 months from end of financial year in which search took place-Order was quashed. [S. 153B, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction was recorded four years after search and two years after assessment of searched person-Notice was quashed and set aside. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheets-Satisfaction note-A sheet of paper containing typed entries and in loose form, not shown to form part of books of account regularly maintained by assessee-Satisfaction note is required to be recorded under section 153C for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings-Power to transfer cases-No reasonable opportunity had been provided before transferring case and officer of Bangalore had sent Notice and Assessment order to assessee who was a resident of Delhi, it was in total violation of section 127-Order of High Court affirmed-SLP of revenue dismissed. [S. 127, 132, Art. 136]

S. 153A: Assessment-Search or requisition-No incriminating material-Order of Tribunal deleting the addition was affirmed-No substantial question of law. [S. 132, 260A]

S. 153A: Assessment-Search-Unexplained investments-Indian nationals and residents had foreign bank accounts in HSBC Bank (Suisse) SA Geneva which were not disclosed to Indian tax authorities-Peak addition-The base note on which revenue sought to place reliance was in fact a document available post-search and admittedly was not a document recovered under search action, and moreover, assessment proceedings had also stood completed, hence, base note being a document available post-search could not be considered to be any incriminating document to assess or re-assess assessee’s income. [S. 69, 132, 147, 148, 260A]

S. 153: Assessment-Reassessment-Limitation-Amalgamation-Order of the High Court did not contain any ‘finding’ or ‘direction’ as contemplated by the provisions of section 153(6)-Order was barred by limitation. [S. 153 (6), Art. 226]

S. 151A: Faceless assessment scheme-Central charge-Notice was issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer, as mandated under the faceless reassessment procedure-Notice and consequential order were quashed and set aside. [S. 148, Art. 226]

S. 151A: Faceless assessment scheme-Reassessment-Notice by Jurisdictional Assessing Officer and not by Faceless Assessing Officer-Reassessment notice and consequential orders were quashed. [S. 147, 148, Art. 226]

S. 149 : Reassessment-Time limit for notice-Notice u/s 148 of new regime on 29-7 2022-Notice issued under old regime on 30-6-2021, with in six year limitation under TOLA is to be treated as notice under section148A(b) of new regime-Notice issued on 29-7-2022 under new regime was in time-Writ petition dismissed. [S. 148, 148A(b), 151, Art. 226]