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]

S. 147 : Reassessment-With in four years-Change of opinion-Deductions on actual payment-Outstanding Rural Development (RD) cess amount as a liability in balance sheet-Rectification proceeding was dropped-All material facts were disclosed before Assessing Officer at time of original assessment-Affirming the order of the Tribunal the Court held that the reassessment is bad in law. [S. 43B, 143(3), 148, 154]

S. 147 : Reassessment-With in four years-Long term capital gains from equities-Instances of insider trading-Formation of opinion based on prima facie, but precise facts-Strong foundation for invoking reassessment-Challenge to notice was dismissed.[S. 10(38), 45, 148, Art. 226]

S. 147 : Reassessment-With in four years-Transfer-Revaluation of asset-Estate development-Converted from inventory to fixed asset-Firm converted into company-Order of Tribunal quashing the reassessment was quashed. [S. 2(47), 45(1), 45(4),47(xiii), 148]

S. 147 : Reassessment-With in four years-Compensation expenditure-Survey-Capital or revenue-Reopening of assessment on mere change of opinion — Impermissible — Notice was quashed and set aside. [S. 37(1), 133A, 147, Art. 226]

S.147: Reassessment-After the expiry of four years-Share capital-No failure to disclose material facts-Reassessment order quashing the reassessment is affirmed. [S. 68, 143(3), 148, 260A]

S. 145 : Method of accounting-Consumption of leather-No suppression of material-Addition was deleted.

S. 144C : Reference to dispute resolution panel-Draft assessment order-Passing of final order-Contrary to law-Mistake could not be cured. [S. 156, 292B.]

S. 144B : Faceless Assessment-Long term capital gains-Violation of principle of natural justice-Allowing the time of 12 hours-Holiday-There was gross violation of principles of natural justice-The final assessment order was quashed.[S. 263, Art. 226]

S. 144B : Faceless Assessment-Neither draft assessment order nor show cause notice was issued-Assessing Officer was directed to initiate process from stage it was left by furnishing draft assessment order along with show cause notice-Matter remanded. [S. 143(3), Art. 226]