S. 151: Reassessment-Sanction for issue of notice-Specified authority-Order under section 148A(d) was passed beyond three years from the end of the relevant assessment year, and approval was obtained from the Principal Commissioner instead of the specified authority required under amended section 151(ii), non-compliance with such statutory mandate and time limits vitiated the jurisdiction of the Assessing Officer, rendering the order under section 148A(d) and notice under section 148 quashed. [S. 148,148A(b),148A(d), 151(i), 151(ii), Art. 226 ]

S. 151: Reassessment-Sanction for issue of notice-Specified authority-Approval granted by the Principal Commissioner was not valid; consequently, the order passed under section 148A(d) and consequential notice issued under section 148 were held to be bad in law and were quashed and set aside. [S. 148,148A(b), 148A(d), 151(ii), TOLA, Art.226]

S. 151: Reassessment-Sanction for issue of notice-Competent authority-Approval granted by the Principal Commissioner was therefore not a valid sanction, and the consequential notice under section 148 and assessment order passed under section 147 were quashed. [S. 148A(b), 148A(d), 151(2), the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3, Art. 226]

S. 151: Reassessment-Sanction for issue of notice-Writ jurisdiction-The assessee had already challenged the assessment in appeal before the Commissioner (Appeals), writ petition challenging reassessment proceedings on the ground of absence of sanction under section 151 was not maintainable, though the assessee could raise such legal contentions before appellate/revisional authorities and the assessment order remained stayed meanwhile. [S.148A,151A, 246A, Art. 226]

S. 149: Reassessment-Time limit for notice-Notice under section 148 dispatched beyond the prescribed time-Notice quashed.[S. 148, 149(1), Information Technology Act, 2000, S. 13(1), Art. 226]

S. 149: Reassessment-Time limit for notice-For AY 2014-15, no notice under section 148 could be issued on or after 1-4-2021 in view of the first proviso to section 149; reopening notice issued on 31-7-2022 was therefore barred by limitation. [S. 147, 148, 148A(b), 148A(d), TOLA, Art. 226]

S. 149: Reassessment-Time limit for notice-limitation period of six years from the end of the relevant assessment year 2015-16 expired on 31-3-2022, notice under section 148 issued on 30-7-2022 was barred by limitation and proceedings under sections 148A and 147 were quashed. [S. 147, 148,148A(d), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order under section 148A(d) quashed-Reassessment order based on such order could not survive-Reassessment order quashed.[S.148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Insolvency proceedings-Resolution Plan approved by NCLT-Revenue having failed to file claim during CIRP-Past claims extinguished-Reassessment proceedings quashed.[S. 148,148A(b), 148A(d), IBC, S. 31, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Interim stay granted by High Court-Strictures-Adjustment of refund-Where High Court by virtue of ad-interim order stayed notice under section 148, assessment order, and restrained revenue from taking further steps, Assessing Officer had no authority to treat stayed notice as one under section 148A(b) or to pass an order under section 148A(d)-Adjustment of refund against stayed demand was also impermissible, and revenue was directed to deposit adjusted amount in court [S. 148, 148A(b), 148A(d), 220, Art. 226]