S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accumulation of income-The Assessing Officer had looked into the relevant details and particulars of accumulation during the course of the original assessment, and the assessee had provided all the details and documents during the original assessment proceedings-The order initiating the reassessment was based not only on a change of mind but also on non-application of the mind-Show cause notice and order quashed. [S. 11(2), 148, 148A(b) 148A(d), R. 17, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Strictures-Assessing Officer before issuance of notice to verify information made available on Insight Portal which suggests that income chargeable to tax has escaped assessment-If necessary, Assessing Officer must conduct inquiry with prior approval of specified authority with respect to such information and only thereafter invoke provisions-Court observed that in future, no such action would be taken by authorities on basis of information made available on Insight Portal without verification by jurisdictional Assessing Officer.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice after six years Limitation-Order passed under section 148A(d) and consequent notice dated 1-5-2024 issued under section 148 after expiry of limitation period of six years on 31-3-2024-Barred by limitation-Faceless assessment-Faceless Assessment Officer has exclusive jurisdiction to issue notice-Notices issued and order passed by Jurisdictional Assessing Officer in contravention of provision invalid-Notice and order set aside.[S. 80-IA, 147, 148, 148A(b),148A(d), Art.226]

S.147: Reassessment-After the expiry of four years-No new material-Change of opinion-Lease back-Notice and consequential proceedings quashed and set aside.[S. 143(1), 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Non eligible assessee-Assessing Officer cannot pass draft assessment order under section 144C(1)-Draft assessment order, final assessment order and notices of demand and penalty set aside. [S. 92CA(3), 143(3), 144C(15), 156, 270A, 271AAC, Art. 226]

S. 143(3): Assessment-Assessment order passed in disregard of principles of natural justice and to be quashed-Strictures-Direction to CBDT –False affidavit by the Revenue before High Court-Assessment order quashed-CBDT is directed to take appropriate action. [S.11, 12, 12A(b) R. 17B, Form No. 10B Art. 226]

S. 143(3): Assessment-Return of income-Revised return of income filed within time-Once revised return filed, original return stands obliterated-Assessment order set aside-Order of Commissioner (Appeals) modified and matter remitted to Assessing Officer. Assessing Officer directed to determine taxable income on the basis of revised return [S.139(1), 139(5), 143(2)]

S. 132B: Application of seized or requisitioned assets-Cash seized-Assessees applying within thirty days of seizure of cash explaining source-No order passed with regard to liability or return Proviso would not come into play-No time line prescribed for recording of satisfaction by Assessing Officer-Release cannot be ordered However, since assessees had informed authorities about cash in bank locker even before recovery thereof, authorities directed to decide assessees’ application within four weeks.[Art. 226]

S. 119: Central Board of Direct Taxes-Circular-Delay of eight days in filing audit report-Technical glitch-Commissioner’s order rejecting condonation application set aside-Commissioner directed to consider audit report and grant all consequential reliefs. [S. 12A, 119(2)(b), R.17B, Form 10B, Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Dealy in filing audit report-Delay of 76 days-Reasonable cause-Genuine hardship-Force majeure-Circular extending period of limitation-Order of Commissioner rejection of application set aside-Matter remanded to the Commissioner for fresh consideration.[S.12A, 119(2)(b), 139, 143(1), Art. 226, R. 17B, Form 10B]