S. 147 : Reassessment–After the expiry of four years – Set-off of long term capital loss against long term capital gain – No failure to disclose material facts–No power of review – Reassessment notice and order disposing the objection was quashed. [S. 74, 143(3), 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years–Commission payment – No failure to disclose material facts-No new tangible material to justify reopening, reassessment proceedings were nothing but a case of change of opinion,- Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years – Shell company -No failure to disclose material facts – Non application of mind – Reassessment notice and order disposing the objection was quashed. [S. 69, 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years – Loans and advances to sister concern – Allegation of colourable device – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed. [S. 69, 148, Art. 226]

S. 147: Reassessment –With in four years- Depreciation – Change of opinion – No new tangible material – Reassessment notice and order disposing the objection was quashed. [S. 132, 143(3), 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years -Purchase and sale of shares – Reopening of assessment to make further additions on account of purchase cost of said shares being based on change of opinion on part of Assessing Officer was not justified– Reassessment notice and order was quashed. [S. 69, 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years – Cash credits – Alternative remedy–Failure to furnish recorded reasons- Alternative remedy is not a bar – Assessment order was quashed. [S. 68, 143(1), 143(2), 144B, 148, 156, Art. 226]

S. 147 : Reassessment–After the expiry of four years – Cash credits – Redemption of preference shares – Source explained in the original assessment proceedings- Change of opinion – Reassessment notice and order disposing the objection was quashed. [S. 68, 143(3), 148, Art, 226]

S. 147 : Reassessment – After the expiry of four years – Cash deposits -Insights portal that certain high risk transactions had taken place in case of assessee which were needed to be verified-No failure to disclose material facts – Re assessment notice and order disposing the objection was quashed. [S. 68, 143(3), 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years – Cash credits – Accommodation entries – Statement of third party – Presumption that the assessee was beneficiary – No tangible material –No failure to disclose material facts – Reassessment notice and order disposing the objection was quashed. [S. 68, 132, 153C, 148, Art. 226]