S. 149 : Reassessment-Time limit for notice-Limitation of six years from end of relevant assessment year-All original notices under section 148 referable to old regime and issued between 1-4-2021 to 30-6-2021 would stand beyond prescribed permissible timeline of six years from end of assessment year 2013-14 and assessment year 2014-15-All notices they would relate to assessment year 2013-14 or assessment year 2014-15 would be time barred as per provisions of Act as applicable in old regime prior to 1-4-2021-These notices could not have been issued as per amended provisions of Act-Notice dated 26-5-2022 issued by respondent-Assessing Officer under section 148, seeking to reopen assessment in respect of assessment year 2014-15 and order dated 30-6-2022 passed under section 148A(d), and all consequential actions, were quashed and set aside-Circulars and Notifications : Notification No. 38 of 2021, dated 27-4-2021.[S. 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Dissonance between input received from insight portal-Non application of mind-Order and notice were set aside. [S. 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Revenue had failed to furnish any (S. 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Purchase of arecanut (Supari)-Failure to give an opportunity of cross examination-Non existence of sellers-Formation of opinion by authority concerned under section 148A(d), could not be questioned on basis of detailed defence setup by assessee on merits of information, including opportunity of cross-examining seller or by demanding documents relating to such information-Writ petition is dismissed. [S. 69A, 143(1), 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Non-Resident Indian-Investment in shares-Automatic route of FDI-Violation of principle of natural justice-Matter was sent back to concerned officer from stage where he committed serious error in not complying with statutory requirements-Order passed under section 148A(d) was quashed and set-aside. [S. 56(2)(vii), 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Civil construction-Objections were dealt with in a very mechanical manner-Order and notice were to be set aside and matter was to be remanded back to pass a fresh order in accordance with law after giving an opportunity of personal hearing.[S. 48, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Capital gains-Search-Violation of principle of natural justice-Without giving a reasonable opportunity to file reply to show cause notice-Order passed under section 148A(d) and notice issued under section 148 were quashed. [S. 48, 148, 148A(b), 148A()d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Survey-Charitable purposes-Prima facie amended section 149 might not be applicable-Matter required examination-Matter to be listed on 22-11-2023-Stay was granted for continuation of reassessment proceedings, till further directions of court. [S. 148, 148A(b), 148A(d), 149, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Educational institution-Deemed university-Order passed under section 148A(d) and consequential notices were quashed. [S. 10(23C)(iiiab), 139(4C), 148, 148A(b), 148A(d), Art. 226]

S. 147 : Reassessment-Special category states-Assessing Officer applied his mind-Proceeding to reopen assessment was actuated merely by a change of opinion and, hence, impugned notice was set aside-Time limit to issue of notice-Notice is not barred by limitation-Sanction obtained satisfaction of Additional Commissioner, an authority who is not covered by provision of section 151(1), as it stood on 1-1-2019, proceeding initiated against assessee-company by issuance of notice under section 148 was held to be not in accordance with law.[S. 80IC, 148, 149, 151 (1), Art. 226]