S. 147: Reassessment-Reassessment order passed in reliance on a superior court ruling after original notices were quashed by the High Court-An unappealed High Court judgment quashing a notice remains final and cannot be bypassed via subsequent universal rulings. [S. 148, 148A(b), 148A(d), 149, Art. 226]

S. 144C: Reference to dispute resolution panel-Reference to TPO under section 92CA was made on 11-01-2022 after expiry of limitation for passing an assessment order under section 153(2) on 31-03-2021; it was without jurisdiction. The order passed under section 92CA (3) on 27-01-2022 and consequential proceedings under section 144C were set aside. [S. 92CA (3), 153(2), Art. 226]

S. 144C: Reference to dispute resolution panel-Transfer pricing-Assessment-Limitation-Remand by Tribunal directly to Transfer Pricing Officer-Second reference by Assessing Officer after Transfer Pricing Officer had already passed order in compliance with Tribunal’s directions-Superfluous and barred by limitation-Assessing Officer deprived of jurisdiction to pass final assessment order. [S. 92CA,, 153(3), 153(4), Art. 226]

S. 144B: Faceless assessment-Objections to draft assessment order-Filed before jurisdictional Assessing Officer instead of Faceless Assessing Officer due to inadvertence-Final assessment order quashed-Matter remanded to Dispute Resolution Panel. [S. 143(3), 144C, Art. 226]

S.143(3): Assessment-Processing of return-Return pending for long period-Authority directed to process return-Expiry of statutory period-Return to be accepted at face value. [143(1)(a), 244A, Art. 226]

S.143(2): Assessment-Notice-Block assessment-Notice served-Notice issued within limitation but served beyond twelve months from the end of the month in which the return was filed-Service of notice is mandatory-Entire proceedings vitiated. [S. 132, 143(3), 158BC, 158BD, 260A]

S. 132B : Application of seized or requisitioned assets-Search and seizure-Application for release within prescribed time-Assessing Officer not at liberty to retain beyond 120 days awaiting crystallization of assessment demand-Order dismissing application quashed-Respondents directed to release seized assets.[S. 132, Art. 226]

S. 132B : Application of seized or requisitioned assets-Jewellery seized from assessee’s employees was requisitioned under section 132A-Stock in trade-Rejection of application by an Assessing Officer not having jurisdiction over assessee or seized assets was invalid; impugned order was to be set aside and matter remanded to concerned jurisdictional officer holding charge over assessee to decide application afresh. [S. 132, 132A, Art. 226]

S. 132B : Application of seized or requisitioned assets-Search and Seizure-Delay of release of seized jewellery solely for unexplained administrative reasons attributable to the Income Tax Dept cannot prejudice the Assessee by requiring them to give a bank guarantee for subsequent increase in market value; seized jewellery was hence liable to be released subject to affidavits of ownership and no objection-CBDT Circular dated 16-10-2023.[S.119, 132]

S. 127: Power to transfer cases-Coordinated investigation-Transfer from Alwar to Faridabad after show cause notice and reasons-Transfer valid. [Art. 226)