S. 153C : Assessment-Income of any other person-Search-Un abated assessments-No addition can be made-Order can be reopened if other conditions are satisfied-Appeal of revenue dismissed. [S. 132,132A, 147, 148, 260A]

S. 153C : Assessment-Income of any other person-Search-
Assessing Officer accepting explanation of searched party that document seized pertained to financial year 2016-2017 and not financial year 2017-2018-Notice issued for assessment year 2018-2019 and consequent assessment order not sustainable.[S. 132(4), Art. 226]

S. 153C : Assessment-Income of any other person-Search-
Period of six years-Commences from date materials forwarded-to review petition dismissed due to delay of 433 days and also on merits. [S. 153A, Art. 136]

S. 153A: Assessment-Search-Search warrants-Laptop containing relevant data found from third party search No incriminating material evidence found from assessee’s premises to justify additions-Held, proceedings under section 153A initiated without incriminating material found from assessee’s premises unsustainable.[S. 132 Art. 226]

S. 151A: Face less assessment scheme-Notice under section 148 issued by jurisdictional Assessing Officer instead of Faceless Assessing Officer-Non-compliance with provisions of section 151A-Notice invalid.[S. 147, 148, 148A(b), 148A(d), Art.226]

S. 151 : Reassessment-Sanction for issue of notice-Specified authority-Grant of approval under section 151 to be in consonance with extended time limits Approval granted by Joint Commissioner not compliant with provisions Notice and assessment order invalid.[S. 147, 148, 149(1)(b), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Limitation-Notice issued beyond six years-Time spent by assessee in earlier litigation can neither be excluded nor can be claimed to result in extension of limitation period-Notice without sanction from prescribed authority-Notices and order invalid.[147, 148, 148A(b), 148A(d), 149(1)(b), 151(ii), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Bogus purchase-Accommodation entries Unexplained income-The Assessing Officer is not required to conclusive determine escaped income at threshold stage-Order and notice for reopening assessment up held. [S. 69, 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Bogus purchases-Accommodation entry providers-Assessing Officer not required to conclusively determine escaped income at threshold stage Order and notice for reopening assessment upheld-Issue regarding jurisdiction of Assessing Officer to initiate reassessment proceedings in faceless assessment regime is no more res integra-Writ petition was dismissed. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Search and seizure-Asset-Limitation-Six or ten assessment years preceding search for which assessment can be reopened-Asset-Assessment year 2016-2017 fell beyond the block of six years the notice issued under section 148 and the reassessment proceedings under section 147 initiated pursuant thereto were set aside. [S. 132, 132A, 147, 148, 148A(b), 148 A(d), 153A(1), proviso 4.]