S. 147: Reassessment-Validity-High-pitched assessment on non-existing entity-Addition made on basis of Multi Year MNS Data without application of mind-Merger of assessee-bank and surrender of PAN ignored-Sanction under S. 151 mechanical-Reassessment was quashed-Exemplary costs of Rs 1 crore was proposed for passing high pitched assessment order contrary to the facts available on record. [S. 144, 148, 151, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Failure to issue notice u/s 143(2)-Error in Form 10CCB regarding date of commencement of production-Date of grant of licence cannot normally be date of commencement of business –Mistake of Chartered Accountant in the Form No 10CCB-No failure to make true and full disclosure-Extended limitation of 6 years not available-Reassessment notice quashed. [S. 80IB, 143(2), 143(3),148, Form 10CCB, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Capital gains-Reopening would amount to review of the assessment order which is not permissible. [S. 148, Art. 226]

S. 144B : Faceless Assessment-Reassessment-No jurisdictional error-Writ petition dismissed. [S. 148, 151, Art 226]

S. 139AA : Return of income-Quoting of Aadhaar Number-Mandatory linkage of Aadhaar with PAN for operation of Demat account-Reasonable restriction on privacy-Provision constitutionally valid. [IT Rules, 1962, R.114AAA, Art. 14, 19(1)(g), 21, 300A]

S. 139 : Return of income-Return declared defective under s. 139(9)-AI-generated order-Principles of natural justice-Alternative remedy of revision-Writ petition dismissed.[S. 44AB,139(9),264, Art. 226]

S. 127 : Power to transfer cases-Co-ordinated investigation-Subjective satisfaction of authorities-Power is administrative in nature and not circumscribed by express language-Transfer justified where search reveals incriminating material across group concerns-No mala fides-Writ appeals dismissed. [Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Return-Condonation of delay-Delay in filing Form No. 10-ID-Reasonable cause-Benefit claimed in return cannot be denied for procedural lapse-Authorities directed to accept belated Form as valid. [S. 119(2)(b), 139, Form 10-IC, Art. 226]

S. 119 : Central Board of Direct Taxes-Instructions-Circular- Revised return-Intimation-Condonation of delay-Refund-Mistake in filling appropriate columns in the return-intimation by CPC-CBDT ought to have condoned the delay in fling the corrected/ revised return-Writ petition allowed. [S. 119(2(b), 139(5), 143(1)(a), 237, Art. 226]

S. 92C : Transfer Pricing-Arm’s length price-Sale of power by eligible unit claiming deduction u/s 80-IA to non-eligible units-Market for electricity regulated-CUP Method-Rates charged by SEB constitute appropriate external CUP. [S. 80-IA(8), 92BA, 260A]