S. 153C : Assessment-Income of any other person-Search- Assessment order passed many years after assessee had filed return-Order passed without giving assessee opportunity to be heard-Order to be treated as notice and assessment to be made after giving assessee opportunity of being heard-The Assessing Officer was directed to provide a reasonable opportunity to be heard, including a personal hearing, and thereafter issue a fresh assessment order within two months. [S. 132, 143(3)]

S. 153C : Assessment-Income of any other person-Search-Objection to jurisdiction-Delay in filing-Writ petition to quash the assessment order is dismissed. [S. 132, Art.226]

S. 151 : Reassessment-Sanction for issue of notice Conducting inquiry, providing opportunity before issue of notice-Not typographical error-Sanction for issue of notice-Principal commissioner-Non application of mind-Approval under section 151 granted without proper application of mind-High Court quashed notices and orders-SLP delay of 181 days-SLP dismissed on grounds of delay and on merits. [S. 148 148A(b), 148A(d), Art. 136]

S. 149 : Reassessment-Time limit for notice-Non-resident-Assets located outside India-Rule against retrospectivity-Intent and language to be considered-Whether new time limit would apply where assessments concluded prior to date of amendment-Matter referred to larger Bench-Finance Act 2012) (2012) 345 ITR 1 (St). [S. 147, 148, 149(1(c), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation-Notice issued to non-existent transferor assessee after court-approved amalgamation-Assessment order passed against dissolved company-Notice and consequential proceedings invalid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Conversion of firm into private limited company-Notice in name of non-existent dissolved firm-Reassessment proceedings initiated against dissolved firm-All transactions actually conducted by successor company using its permanent account number-Department’s failure to consider conversion despite intimation Notice issued under section 148 and reassessment proceedings and reassessment order passed in name of non-existent firm set aside.[S. 142(1) 144, 144B, 147, 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Initial notice allowing five days to reply-Minimum seven days required to be granted under statute for assessee to respond-Assessee filing reply after five days-Order and notice set aside with direction to Assessing Officer to consider reply filed by assessee and pass appropriate order.[148, 148A(b),148A(d), 151, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice giving assessee less than seven days-Notice invalid-Limitation-Extended period of limitation Income alleged to have escaped less than fifty lakh rupees-Notice after three years-Barred by limitation.[S. 147, 148, 148A(b), 148A(d), 149(1)(a), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Interest income on bank deposits-Order dated 22-10-2019 of National Company Law Tribunal writing off of bank loans and waiving off of statutory dues Notice and order quashed and set aside Income.[S.127(2), 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order passed without considering the reply-Pendency of appeal-Directions were to be issued to the appellate authority to dispose of the appeals within a stipulated time frame, pursuant to which, the respondents could be directed to reconsider the matter afresh in accordance with law. [S. 148A(b), 148A(d), 250, Art. 226]