S. 254(1): Appellate Tribunal-Powers-Additional grounds-Challenge to validity of reassessment raised before Commissioner (Appeals) and rejected-Assessee in Department’s appeal filing application raising ground relating to validity of assessment-Tribunal justified in accepting ground and holding reassessment was on change of opinion and unsustainable in law.[S. 147, 148, (Appellate Tribunal) Rules, 1963, R. 27.]

S. 254(1): Appellate Tribunal-Powers-Limitation-Condonation of delay-Mistake of counsel by itself not always a sufficient ground-Delay of six years and 83 days-Order of Tribunal dismissing.

S. 254(1): Appellate Tribunal-Powers-Limitation-Condonation of delay-Delay of six to seven years-Tribunal finding lack of bona fides and gross negligence on part of assessee-Assessee aware of orders passed by Commissioner (Appeals) but tried to place responsibility on counsel-SLP of assessee dismissed. [Art. 136]

S. 158BC: Block assessment-Return-Search-Seizure of books of account-Return delayed-Tribunal treated delayed return as ‘non-est’ without considering impact of search and double taxation-Order was set aside, and matter was to be remanded for fresh adjudication. [S. 139(1), 158BB(1(ca), 158BC, 260A]

S. 153C: Assessment-Income of any other person-Search-Satisfaction note-Time limit for passing assessment order to be reckoned from 22-6-2022-Last date for passing assessment order has expired on 31-3-2024-Proceedings barred by limitation-Notice quashed and set aside.[S. 132, 153B, Art. 226]

S. 153A: Assessment-Search-Unaccounted income –Capital gains-Statement retracted-Retracted statement could not be termed as incriminating material-No addition could be made in respect of completed assessments on the basis of such retracted statement. [S. 132 (4), 132A, 260A]

S. 153A : Assessment-Search or requisition-Warrant of Authorisation-Panchnama-No search against the assessee-Panchanama reflected the name of the assessee-Panchnama cannot be treated as warrant of authorisation-Assessment order is quashed as without jurisdiction-Existence of alternative remedy-Not bar to entertainment of writ petition where challenge is to jurisdiction exercised by Authority and interpretation of statutory provisions involved-SLP of revenue dismissed. [S. 132,153D, Art.136]

S. 151A: Faceless assessment scheme-Jurisdiction to issue notice of reassessment lies with the faceless Assessment Officer, not the jurisdictional Assessing Officer-Notice and consequential order invalid.[S. 147, 148, 148A(b) 148A(d), Art.226]

S. 151A: Faceless assessment scheme-Faceless Assessment-Reassessment-Jurisdiction-Mandatory-Notices and orders issued by jurisdictional Assessing Officer-Invalid and to be quashed-Liberty to Department to revive petitions if Supreme Court holds in its favour. [S. 148 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accumulation of income-The Assessing Officer had looked into the relevant details and particulars of accumulation during the course of the original assessment, and the assessee had provided all the details and documents during the original assessment proceedings-The order initiating the reassessment was based not only on a change of mind but also on non-application of the mind-Show cause notice and order quashed. [S. 11(2), 148, 148A(b) 148A(d), R. 17, Art. 226]