S. 151A: Face less assessment scheme-Notices issued by jurisdictional Assessing Officer quashed and set aside-In a taxing statute, one has to look at the text as it is. There is no equity in taxation law. There is no intendment and presumption as to tax-Nothing is to be read in and nothing is to be implied- Revenue granted liberty to issue fresh notices in compliance with Central Board of Direct Taxes circular read with section 151A of the Act – Interpretation of taxing statue-term “randomly”. [S. 147, 148, 148A(b) 148A(d), Art. 226, 265]

S. 151A: Face less assessment scheme-Notice under section 148 issued by jurisdictional Assessing Officer instead of Faceless Assessing Officer-Non-compliance with provisions of section 151A-Banking business-Capital or revenue Purchase of securities-Broken period interest-Allowable revenue expenditure-Audit objection-Notice invalid.[S. 147, 148, 148A(b), 148A(d), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information found recorded in coded electronic books of account of searched party – No scrutiny assessment – Reassessment notice is valid – Limitation-Quantum of escapement of income Limitation for assessment year 2017-2018 existing beyond 31-3-2021- Reassessment proceedings within prescribed time limit of six or ten years.[S. 147, 148, 148A(d), 153, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice – Diversion of loan- Proceedings continued under section 148A pursuant to direction of Supreme Court in UOI v. Ashish Agarwal( 2022) 444 ITR 1 (1) (SC) – Reassessment proceedings held to be valid. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Not granting sufficient time to reply-Principal Commissioner granting approval for notice prior to digitally signing of initial notice and passing of order for issue of notice for reassessment-Notice and order not valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- limitation-Notice issued after expiry of six years from relevant assessment year barred by limitation [S. 147, 148, 148A(b), 148A(d), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Limitation-Time limit of four years reduced to three years for all situations-Time limits of four years and six years from end of relevant assessment years specified under Act not affected Assessing Officer required to issue notice for reopening assessment under section 148 of new regime within limit of surviving period under Act read with 2020 Act- Notice dated 29-7-2022 issued beyond surviving period of 2-7-2022 for assessment year 2013-2014 barred by limitation-Order for issue of notice and notice and consequent assessment order quashed and set aside. [S. 144B, 147, 148, 148A(b), 148A(d), 149 (1), Income-tax Act, 1961, ss. 144B, 147, 148, 148A(b), (d), 149(1) Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accepting information furnished by assessee-Order for conducting further enquiry-Not valid. [S. 147, 148, 148A(b), 148 A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice – Limitation- Issue of notice under new regime not permissible if time barred under old regime-By virtue of TOLA, Assessing Officer had period of twenty-nine days limitation left on date of commencement of reassessment proceedings to issue a notice under section 148-Notice dated 30-7-2022 for Assessment Year 2013-14 issued beyond period of limitation – Order and consequential notices set aside. [S. 144, 144B, 147, 148, 148(A)(b), 148A(d), 149, TOLA, 2020, S 3(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation – Fresh notice issued as per Supreme Court directions in UOI v. Ashish Agarwal( 2022) 444 ITR 1 (SC))- Fresh notice following new procedure issued in correct name of assessee Reassessment proceedings not vitiated by incorrect name in original notice-Reassessment proceedings under fresh notice valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]