S. 147 : Reassessment -After the expiry of four years -No failure to disclose material facts -Change of opinion – Reassessment notice and order disposing the objection was quashed by the High Court was affirmed. [S. 143(3), 148, Art. 136, 226]
S. 147 : Reassessment -After the expiry of four years -No failure to disclose material facts -Change of opinion – Reassessment notice and order disposing the objection was quashed by the High Court was affirmed. [S. 143(3), 148, Art. 136, 226]
S. 147 : Reassessment-Notice after six years-Notice issued prior to 1-4-2021 more than six years after expiry of Assessment year – High Court quashed notice and orders- SLP of Revenue is dismissed. [S. 148, Art. 136, 226]
S. 144B : Faceless Assessment-Writ-Territorial Jurisdiction of Court -Doctrine of forum non convenience – Assessment order -Cause of action – Situs of Assessing Officer would be determinative of Jurisdiction of High Court -Complexity of Legal issues -Matter referred to larger Bench. [S. 143(3), 144B(1)(xxxii), 156, 271AACC (1), Art. 226]
S. 144B : Faceless Assessment-Failure to follow the procedure-Certain observations of High Court is expunged-Liberty to Department to seek review in light of omission of section 144B(9) of the Act. [S. 144B(9), Art. 136, 226]
S. 144B : Faceless Assessment –Failure to follow procedure -Subsequent omission of provision -Judgment of High Court set aside and matter remanded to the High Court to consider effect of omission of provision. [S. 119, 144B (9), Art, 136, 226]
S. 144B : Faceless Assessment –Draft assessment order -Failure to issue notice and draft assessment order -Non est -Matter remanded to Assessing Officer to assess afresh. [Art. 136, 226]
S. 144B : Faceless Assessment -Failure to serve draft assessment order- Order set aside -Order of High Court affirmed -SLP of Revenue dismissed -Liberty is given to the Revenue to proceed in accordance with the law. [Art. 136, 226]
S. 144B : Faceless Assessment-Failure to follow procedure-Order declared non-est-liberty is given to the Department to revive the special leave petition in case of difficulty or if the necessity arose. [S. 144B(9), Art. 136, 226]
S. 144B : Faceless Assessment –Failure to issue show cause notice and draft assessment order —Order of High Court is not erroneous -Judgment modified and matter remanded to Assessing Officer to pass fresh assessment order. [144B(1) (xvib), Art. 132, 226]
S. 144B : Faceless Assessment-Failure to serve draft assessment order -Department was allowed to file Review Petition before High Court to consider effect of omission of Section 144B(9) with effect from 1-4-2021. [S. 144B(9), Art. 136, Art. 226]