S. 179 : Private company-Liability of directors-Recovery of tax-Burden of proof-Non-recovery of tax was not attributable to gross negligence, misfeasance or breach of duty by directors Initiation of action after period of eight years-Order and revision order is quashed. [S. 264, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Examination of disputed questions of fact-Alternative remedy-Writ petition is dismissed.[S. 144 153A, Art. 226

S. 153A : Assessment-Search-Statement made during search has evidentiary value but by itself cannot be basis for assessment-Assessment completed before search-No incriminating material was found-Distinction between scrutiny assessment under section 143() and summary assessment under section 143(1) is irrelevant for the purpose of section 153A-Addition is not justified-Question of fact. [S. 132,132(4), 143(1), 143(3), 260A]

S. 153A : Assessment-Search-No incriminating material was found during search-Original assessment completed-Order is not valid. [S. 132]

S. 153A : Assessment-Search-No incriminating material found during search-Statement recorded under Section 132(4) does not constitute incriminating material-Completed assessment-Addition is not valid. [S. 132, 132(4)]

S. 151 : Reassessment-Sanction for issue of notice-Notice issued after expiry of six years from assessment year-Sanction of Additional Commissioner-Sanction is not valid-Taxation and other Laws (Relaxation and Amendment Of Certain Provisions) Act, 2020 is not applicable.[S. 148, 151(1), Art. 226]

S. 149 : Reassessment-Time limit for notice-Capital gains-Dissolution of firm in 2006-Notice issued for reassessment for the Assessment year 2007-08 in November 2014-Notice is barred by limitation. [S. 144, 147, 148, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Risk Management Strategy-Information Received From Director (Investigation And Criminal Intelligence)-Suffice requirement of information-Consideration for moveable property excess of Rs 50 lakhs-Sanction form Principal Commissioner-Reassessment notice is valid.[S. 147, 148, 148A(b), 148A(d), 149(1)(b), 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Alternate remedy-Not absolute bar for filing writ petition-Writ petition is admitted.[S. 147 148, 148A(b), 148A(d),246A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order passed in Permanent Account Number which had been surrendered-Direction of single judge to file representation-Notice and order set aside-Directed to pass speaking order.[S. 148, 148A(b), 148A(d), Art. 226]