S. 153A : Assessment-Search or requisition-Sanction of prescribed authority-Mechanical sanction-Assessing officer passing draft assessment order and on same day approving authority granting approval for 123 assessees-impossible for a person to apply his mind on all cases for all in a single day-Approval is illegal and non est. [S. 132, 153D, 260A]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Failure to afford opportunity of hearing-Order and notices set aside-Matter remanded to assessing officer. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Order passed without considering the reply-Order set aside-Matter remanded to assessing officer to consider reply and afford opportunity of hearing. [S. 147, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Reply was uploaded on Monday immediately after public holiday and Saturday and Sunday-Order for issue of show-cause notice without considering reply-Order passed in haste reducing procedure to nullity-A purposive interpretation needs to be given to the statutory provision-Matter was remanded-Directed the respondent to pay cost of Rs. 15000, however on request of the Departmental counsel who has assured that he will take responsibility of conveying as to what would mean by “reasonable opportunity to the assessee“-Portion of direction imposing cost on the Departmental Officer was deleted. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Survey-Salary or professional income-Remuneration is not taxable as salary-Remuneration of Doctors working in hospital-Issue of notice without examining the contracts between hospital and doctors-Order and notice not valid. [S. 133A, 147, 148, 148A(d), 149A(d), 192, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Natural justice-Failure to grant minimum seven days of time to file reply to notice-Notice for reopening of assessment set aside-Matter remanded to assessing officer. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessee is not expected to prove negative fact-Assessing Officer should verify information collected from other sources-Information not verified-Order is not valid-Directed to pass fresh order after giving a reasonable opportunity of hearing. [S. 147, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Sale of property-Alleged cash receipts-Capital gains-Tax evasion petition on insight Portal-Directed to provide all documents considered by him as information-Order and subsequent notice set aside-Directed to pass the order after considering the reply of the assessee. [S. 147, 148, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Assessing Officer was directed to supply with material relied-Order and notice set aside-Liberty granted to Department to pass fresh order if necessary. [S. 147, 148, 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Assessing officer vested with jurisdiction over assessee can issue notice-Pecuniary limits had been laid down for distribution of work among assessing officers would not divest assessing officer of his jurisdiction-Notice valid. [S. 120, 124, 147, Art. 226]