S. 153C: Assessment-Income of any other person-Search-Additions based on a survey conducted in premises of assessee and not based on incriminating material found/seized during search and neither recorded in ‘Satisfaction Note’ during assessment under S. 153C cannot be sustained and deserves to be deleted.[S. 133A, 260A]

S. 153C: Assessment-Income of any other person-Search-Material related to assessee being other person found during search and handed over to AO-Assessment ought to have been made under S. 153C and not S. 143(3) of the Act-Order of Tribunal quashing the addition is affirmed. [S. 143(3), 260A]

S. 153A: Assessment-Search-No incriminating material is found-The Assessing Officer (AO) can only reopen assessments for the block period of six years if incriminating material related to each specific year is found during the search and not otherwise-Order of Tribunal is set aside. [S. 132, 158BB, 260A]

S. 153A: Assessment-Search-Additions unsustainable in the absence of incriminating material for unabated assessments-No addition can be made-Order of Tribunal is affirmed. [S. 132, 133A, 153C, 260A]

S. 153 : Assessment-Reassessment-Limitation-When there is no finding or direction in terms of clause (i) of sub-section (6) of Section 153, the extended time shall be 60 days, as specified in the first proviso to Explanation 1 of Section 153, rather than 12 months-Direction-Inconsequence of-To give effect to-Finding-Assessment order is barred by limitation. [S. 143(3) 144B, 147, 148, 153(3)(ii), 153(6), 260,Income Tax Act, 1922, S. 34(3), Art. 226]

S.151A : Faceless assessment of income escaping assessment-Notices under section 148 must be issued in a faceless manner through automated allocation as per section 151A and the notification dated 29-3-2022. The Jurisdictional Assessing Officer (JAO) lacks the authority to issue such notices, rendering them illegal and invalid. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S.151A : Faceless assessment of income escaping assessment-Reassessment-Notice issued by Jurisdictional Assessing Officer instead of Faceless Officer held to be without jurisdiction [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 150: Assessment-Order on appeal-Conditions set out in S. 150 are required to be fulfilled for invoking S. 150 for issuance of notice under S. 148 beyond the period stipulated under S. 149-Appeal of Revenue is dismissed. [S. 148, 149, 254(1), 260A]

S. 149 : Reassessment-Time limit for notice-Provisions of relevant assessment year applicable for reassessment proceedings. [S. 147 148,149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Incorrect premise-Reassessment notice based on incorrect assumption of non-filing of return-Held to be invalid-Order cannot be justified on basis of reasons supplied subsequently-DTAA-India-Mauritius [S. 9, 147,148, 148A(b), 148A(d), Art. 13(4), Art. 226]