S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Initial notice-Notice calling upon assessee to submit various details for verification of data-Notice could not have been issued for verification-Notice not commensurate with the requirement of clause (b) Not sustainable.[S. 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-High Court held that the order for issue of notice for reopening assessment was not in accordance with procedure prescribed and hence was unsustainable; SLP of revenue dismissed in view of concession made by Department in UOI v. Rajeev Bansal (2024) 469 ITR 46 (SC) [S.147, 148, 148A(b), 148A(d), Art. 136]

S. 147: Reassessment-Summary assessment-Assessing Officer not precluded from re-opening assessment-Appeal to Appellate Tribunal Powers of Tribunal challenging finding of Commissioner (Appeals) with regard to jurisdiction of Assessing Officer to reopen assessment-Tribunal possesses ample power to decide any issue going to the root of the subject matter-Assessee’s objection that Tribunal could not have taken upon itself to decide it not tenable [S. 56,,143(1), 148, 254(1), 260A]

S. 147: Reassessment-Interim dividend income-Mercantile system of accounting-Accrual-Right to receive interim dividend arose on 14-3-2002 in financial year 2001-2002 relevant to assessment year 2002-2003-Reassessment order was quashed-Order of Tribunal affirmed.[S.10(33), 143(3), 148, 260A]

S. 144C: Reference to dispute resolution panel-Remand by the Tribunal-Draft assessment order is mandatory-Order of single judge dismissing writ petition set aside [S.92C, 92CA, 254(1), Art. 226]

S. 144B : Faceless Assessment-Reassessment-Procedure complied with-No jurisdictional error-Alternative remedy-Writ petition dismissed-Statutory appeal period of delay due to pendency of writ petition to be condoned in application, if any, for condonation of delay. [S.144, 148, 151, Art. 226]

S. 143(2): Assessment-Notice-Expiry of prescribed period for service of notice falling on Sunday-Sunday being postal holiday notice served on subsequent day of Monday valid.[S. 2(15) 11, 13, 260A, General Clauses Act, 1897, S. 10.]

S. 119: Central Board of Direct Taxes-Circular-Concessional tax regime-Condonation of delay-Delay in filing Form 10-IC-genuine hardship-Order of Principal Commissioner rejecting application quashed and set aside. Directions issued to the Revenue to accept the assessee’s Form 10-IC and recompute tax liability accordingly.[S,.115BAA, 119(2)(b), Art. 226]

S. 115BAA: Tax on income of certain domestic companies–Concessional tax regime-Assessee company had not exercised its option to avail benefit of section 115BAA before the due date specified under section 139(1) in its return; it could not be allowed to revise its return and file Form 10-IC after the due date for filing return under section 139(1) so as to avail benefit of lower taxation under section 115BAA.[S.115BAA(5), 139(1) Art. 226]