S. 147 : Reassessment-Capital gains-Exemption under S. 54F-Investment in a residential house-Separate floors of same house purchased by family members-To be regarded as one residential house-No failure to disclose material facts-Reopening invalid [S. 45, 54F, 260A]

S.147: Reassessment-After the expiry of four years-Deduction claimed twice-Reassessment is justified.[S.37(1), 148, Art. 226]

S. 147: Reassessment-After the expiry of four years-Double deduction-Failure to disclose fully and truly all material facts-Reopening valid-Writ not maintainable when alternate remedy availed-Order of Single Judge affirmed.[S. 37(1), 148, Art. 226]

S. 144C : Reference to Dispute Resolution Panel-Transfer pricing-Assessment pursuant to Tribunal remand-Failure to pass draft assessment order-Assessment order passed without complying with section 144C procedure is void and illegal..[S.92CA, 144C(1), Art. 226]

S. 143(3) : Assessment-Principle of natural justice —Strictures-Assessment order passed without granting or rejecting adjournment request-Systemic deficiencies in faceless assessment and portal functioning resulting in violation of rule of law-Assessment, penalty and demand orders quashed-Work Domain-Directions issued to strengthen tax administration and ensure compliance with Court orders-Costs were imposed on the Department. [S 156, 270A, Art. 226, 265]

S. 143(3) : Assessment-Principles of natural justice-Opportunity of being heard-Notices sent to email address available on MCA website-Assessee having participated in assessment proceedings precluded from objecting to service of notice-No violation of natural justice-Writ petition dismissed. [S. 142(1), 282, 292BB, R. 127(2)(b)(iii) of the Income-tax Rules, 1962, Art. 226]

S. 143(3): Assessment-Notice under S. 143(2) issued by ITO lacking pecuniary jurisdiction-Assessee participated in proceedings before Dy. CIT without objection-Objection raised for first time before Tribunal barred by S. 292BB-Tribunal erred in quashing assessment-Matter remanded. [S. 143(2), 254(1), 260A, 292B, 292BB]

S. 132A : Powers-Requisition of books of account, etc.-Assets in custody of Police-Criminal case-Stolen property seized by police-Department cannot claim possession by issuing notice under s. 132A-Separate proceeding can be initiated only after decision of Court. [CrPC, 1973, Ss. 397, 401, 457]

S. 132: Search and seizure-Authorisation-“Reason to believe”-Satisfaction not perverse-Search action valid-Prohibitory order under S. 132(3) ceases after 60 days by virtue of S. 132(8A). [S. 132(3), 132(8A), Art. 226]

S. 127 : Power to transfer cases-Revocation of transfer order during pendency of writ and finalisation of assessments-Volte-face without reasons-Strictures passed-CBDT and Ministry of Finance directed to conduct enquiry. [S. 119, 127(2), Art. 226]