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]

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- SLP of assessee dismissed.[S. 147, 148, 148A(b), 148A(d), Art. 136]

S. 147 : Reassessment-Search and seizure-Reassessment-Reassessment pursuant to search carried out prior to 1-4-2021-Orders quashed.[S. 132, 148, Art. 226]

S. 147 : Reassessment-Change of opinion – Notice based on assessment order of subsequent assessment year-Non-deduction of tax at source on payment made to non-resident, short and long term gains on share transactions- Provision for warranty – Deduction u/s 35(2AB )-No independent formation of opinion by Assessing Officer based on new material-Reassessment notice quashed and set aside. [S. 35(2AB), 148, Art. 226]

S. 147 : Reassessment – Survey-Non-resident-Permanent establishment Permanent agent- Dependant establishment-Attribution of profits – Reassessment notice was up held by the Tribunal – No substantial question of law – Appeal dismissed-Rejection of application for recall of the order was affirmed. [S. 148, 254(2), 260A, Art. 226]

S. 147 : Reassessment-Notice – Subject matter of appeal-Income which is subject matter of appeal, reference or revision – Reassessment notice is not valid [S. 11, 148, Art. 226]

S. 147 : Reassessment-Search and seizure-Reassessment-Assessment of third person-Notice opportunity of hearing not mandatory for issue of notice of reassessment pursuant to search-Satisfaction note is internal communication of Department not requiring document identification number-No provision requiring supply of copy of satisfaction note to assessee with notice for reopening assessment -Writ petition dismissed. [S. 132, 148, 153A, Art. 226]