S. 148 : Reassessment –Notice-Additional grounds-Legal grounds admitted-Recorded reasons under wrong premises-Reassessment proceedings void ab initio-Sanction-Approval granted mechanically-Notice and all consequent proceedings liable to be quashed.[S.147, 151]

S. 148: Reassessment-Notice-Fishing enquiry-Recorded reasons are identical with information received-Foundation of reasons not existing when reasons recorded-Recorded reasons invalid-Assessments are quashed. [S. 147]

S.147 : Reassessment-Cash credits-Protective assessment–Held reopening assessment to make addition on the protective basis is bad in law-Amounts to reopening merely on suspicion-Reassessment is quashed. [S.68, 148]

S.147:Reassessment-Reasons recorded-To be examined on a standalone basis-Reassessment is held to be bad in law. [S.92CA, 148]

S. 147 : Reassessment-Educational institution-Application of 85 percent of gross income is not a requisite condition for exemption-Claiming exemption under section 10(23C)(iiiad)and not under section 11(1)(a)-Reassessment is not valid.[S. 10(23C)(iiiad), 11(1)(a), 12A]

S. 147 : Reassessment-Interest-No fresh material-Change of opinion-Reassessment is not valid.[S.37(1), 80IA 143(3), 148]

S. 147 : Reassessment-After the expiry of four years-Re-appreciation of same documents which were available at the time of original assessment-Reassessment is quashed.[S.143(3)]

S.144C: Reference to dispute resolution panel-Since there was no forwarding not even effort to forward draft assessment order to the new address furnished to the Assessing Officer under proviso to Rule 127(2) within permitted time frame under section 153 r.w.s. 144C, the impugned assessment order was time barred and therefore liable to be quashed. [S. 153, Rule 127(2)]

S. 144C : Reference to dispute resolution panel-Assessing Officer issuing notice of demand on same date as draft order attaining finality to assessment-Once notice of demand issued, assessment complete-Assessment order is not valid. [S.143(3), 156]

S. 144 : Best judgment assessment-Rejection of books-Estimate of net profit at 4 Per Cent. on gross turnover-Justified-Fixed Deposits utilized to acquire bank guarantee-Nexus between interest earned and interest paid-Interest paid to be adjusted against interest received.[S.56, 57, 145(3)].