S. 149 : Reassessment-Time limit for notice-Assessing Officer issued notice under section 148 (old regime) on 30-6-2021-A notice under section 148A(b) was issued on 20-5-2022-Assessee filed a reply on 3-6-2022-Assessing Officer passed an order under section 148A(d) and also issued a notice under section 148 on 28-7-2022-Order passed under section 148A(d) dated 28-7-2022 and notice issued under section 148 dated 28-7-2022 were to be held as beyond time.[S. 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Suspicious Transaction Report (STR)-Assessee had fully disclosed income and justified the same in reply filed before authorities-Reassessment notice and consequential orders were quashed and set aside. [S. 148, 148AI(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Income from other sources-Real estate development-Stock-in-trade-Absence of any new tangible material and where provisions of section 56(2)(x) were not applicable on merits, initiation of reassessment proceedings was unsustainable.[S. 56(2)(x), 148, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Property held for charitable purposes-Accumulation of income-Once conditions of section 11(2) were satisfied, accumulated income could not be included in total income, and the Assessing Officer had no discretion to deny such benefit-Reassessment notice and consequential order were quashed and set aside. [S.11(2),12A, 139(1),148, 148A(b), 148A(d), Form No 10, R. 17, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Reassessment notice was quashed-Reassessment order based on the quashed order will not survive-Delay of 429 days-SLP of revenue dismissed on account of delay. [S. 148, 148A(b) 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Depreciation-Goodwill-Audit objection-Non-application of mind-Order of High Court affirmed-SLP of revenue dismissed. [S. 32, 148A(b), 148A(d), Art. 136]

S. 148: Reassessment-Notice in the name of a dead person-Reassessment notice and order were quashed and set aside. [S. 147, Art.226]

S. 147: Reassessment-Export business-Original assessment order did not indicate any application of mind by Assessing Officer on issue of deduction under section 80HHC-Assumption of jurisdiction under Section 147 was justified, as income was admittedly subject to excessive relief under section 80HHC. [S.80HHC, 148, 260A]

S. 147: Reassessment-Non-Resident-Permanent Establishment-Transactions found to be at arm’s length-Supplying materials through direct imports to Indian Railways-Allegation of wholly owned subsidiary-No material to prove conclusively that Indian Subsidiary’s place assessee’s Permanent Establishment falling in any of three Categories-High Court quashed the reassessment-Order of High Court affirmed-SLP of revenue dismissed DTAA-India-USA. [S. 92CA, 133A, 148, Art. 5(1), 5(2), 5(3), 5(4)]

S.147: Reassessment-Cash credits-Share capital-Nature and source of receipts had been satisfactorily explained/proved, and the Assessing Officer had not contradicted the explanation/information given by the assessee-Reassessment notice and consequential orders were quashed-SLP of revenue dismissed on account of delay of 198 days and also on merits. [S. 68, 148, Art. 136]