S. 147 : Reassessment-After the expiry of four years-Compensation-Business expenditure-No new tangible material-Assessee had filed reply during original assessment proceedings-twin conditions-New tangible material and failure on the part of the assessee to disclose all material facts truly and fully, does not exist-Notice and order disposing the objection is quashed. [S. 37(1), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Reopening of assessment on the basis of decision of court that approval not obtained from competent authority-not a case of income escaping assessment due to failure on the part of the assessee to disclose material facts during the course of assessment-reopening unjustified.[S.10B, 148, Art. 226]

S. 147:Reassessmet-After the expiry of four years-Change of opinion cannot be a reason to reopen the assessment.[S. 35D, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Money transferred to assessee’s bank account from cash deposits in other persons bank account-Borrowed Satisfaction-Mere increase in funds from previous year-No Tangible material on record-Notice and order disposing the objection is quashed.[S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Capital Gains-Full value of consideration-Stamp Duty Valuation-Reassessment notice and order disposing the objection is quashed.[S.45, 50C, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Change of opinion-Direction of Audit party-Amalgamation-AO issued notice on the ground of directions issued by the audit party-Being not on AO’s personal satisfaction, reopening of assessment without any basis, merely on change of opinion and not permissible in law-Reassessment notice and order disposing the objection is quashed.[S. 72A(4), 148, Art. 226

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed.[S. (2(22)(e), 147, 148, Art. 226]

S. 144B: Face less assessment-Reassessment-Principle of natural justice-Technical glitch-Order is set aside.[S. 147, 148, Art.226]

S. 144B : Faceless Assessment-Video Conferencing not granted by the Assessing Officer-Grave abrogation of jus naturale-impugned assessment order is set aside.[S. 144B(6) (viii), 147, 148, Art. 226]

S. 144B : Faceless Assessment-Principles of natural justice-At least 21 days time should be given to file reply-Legislative Intent is to provide an opportunity of being heard to the assessee before passing any orders, which are prejudicial to their rights/interests-It is bounden duty of the Assessing Officer to pass a detailed order, providing reasons for rejection of the contention of the assessee-Matter restored to the file of the AO as the assessee was granted time of 5 days only without referring to opportunity of personal hearing.[Art. 226]