S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice issued pursuant to directions of Supreme Court in UOI v. Ashish Agarwal (2022) 444 ITR 1 (SC)-Notice signed digitally on 31-3-2021 and placed on portal-Notice dispatched through e-mail sent and speed post on 1-4-2021-Where notice sent electronically, date of dispatch of e-mail to be considered as date of issue of notice not barred by limitation [S. 147, 148, 148A(b), 148A(d), 149(1), Art. 226]

S. 147 : Reassessment-No fresh tangible material-Change of opinion-Claims under section 35AC and deductions under section 80G examined and allowed in scrutiny assessment-No new material found to reopen completed assessment-Reassessment not valid. [S. 35AC, 80G, 143(3) 148, Art. 226]

S. 147 : Reassessment-Search and seizure-Assessment of third person-S. 153C is an enabling provision and does not automatically override S. 147-In absence of satisfaction note and transfer of seized material by Assessing Officer of searched person, jurisdiction under S. 153C not assumed-Reassessment under S. 147 valid-Tribunal erred in holding that S. 153C had overriding effect merely because search was conducted-Matter restored to Tribunal to decide other grounds. [S. 132, 147, 153C, 260A]

S. 147 : Reassessment-Cash credits-Assessment not relating to reasons recorded-Order of Tribunal deleting the addition is affirmed. [S. 68, 148, 260A]

S. 147 : Reassessment-Cash credits-Accommodation entries-Addition made on different grounds not forming part of reasons for reopening of assessment-Once principal grounds on which reassessment was proposed are dropped, no further additions can be made even by taking recourse to Explanation 3 to section 147-Order of Tribunal deleting the addition is affirmed. [S.68, 147, Expln. 3 148, 260A]

S. 147 : Reassessment-After the expiry of four years-Search and seizure-Original assessment made pursuant to search and seizure based on appraisal report and materials seized during search and seizure operations-Reassessment notice based on audit objection which was based upon same appraisal report-Notice not based on new material coming to notice of Assessing Officer-Not sustainable–Limitation Four to six years counted from end of assessment year Notice for assessment year 2014-2015 dated 31-3-2021 not barred by limitation–Reassessment-Notice after four years-Sanction of prescribed authority-Law before amendment with effect from 1-4-2021-Principal Commissioner competent to accord permission for reopening of assessments beyond four years-Assessing Officer digitally signing notice on 31-3-2021 at 7.01 p.m.-Notice goes beyond control of Assessing Officer at that moment Notice within prescribed time limit-Generation of document identification number by online portal on 1-4-2021 would not render notice barred by limitation. [S.132, 148, 149(1)(b), 151, Art.226] .

S.147: Reassessment-After the expiry of four years-Suspicion-Information received from Investigation Wing-No independent examination-Reassessment notice and order disposing the objection was quashed and set aside.[S. 148, Art. 226]

S.147: Reassessment-After six years-Search and seizure-Cash credits-Share application money-Failure to issue notice-Reassessment based on suspicion-Deletion of addition by Tribunal is affirmed. [S. 68,133(6), 148, 260A]

S. 147 : Reassessment-After the expiry of four years-Set off the losses incurred in one unit against the profits of the other unit-Audit objection-Change of opinion-Notice and consequential proceedings quashed-Circular No. 7/DV/2013 dated July 16, 2013 (2013) 356 ITR (St.) 7).[S.10A, 10AA, 148, 151]

S. 144B : Faceless Assessment-Personal hearing not granted-Matter remanded to Assessing Officer-Violation of principles of natural justice Assessee need not be relegated to statutory remedy of appeal.[S. 143(3), Art.14, 226]