S. 147 : Reassessment-Wrong recording of reasons-Recorded reasons refers sale of property-Non application of mind-Notice and order was quashed and set aside. [S. 148, Art. 226]
S. 147 : Reassessment-Wrong recording of reasons-Recorded reasons refers sale of property-Non application of mind-Notice and order was quashed and set aside. [S. 148, Art. 226]
S. 147 : Reassessment-Change of opinion-Reassessment notice and order was quashed. [S. 115JB, 148, Art. 226]
S. 147 : Reassessment-Weighted deduction-Recorded reasons-Added in the assessment order-No failure to disclose fully and truly all material facts-Failure to deal with the objections raised by the petitioner-Reassessment notice and subsequent order was quashed. [S. 35(2AB), 148, Art. 226]
S. 147 : Reassessment-With in four years-Waiver of loan-Change of opinion-Query raised during regular assessment proceedings-Order of Tribunal affirmed. [S. 28(iv), 41(1), 148]
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Quarries raised during assessment proceedings-Notice is held to be bad in law and quashed. [S. 148, Rule 11UA, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Change of opinion-No failure to disclose material facts-Not dealt with any of the submissions-Referred 68 case laws without stating how the case laws are applicable to the facts of the petitioner-Reassessment notice is bad in law [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Deemed dividend-No failure to disclose truly and fully material facts-Referred 68 cases laws however not stated how case laws are applicable to the facts-The Order was quashed by observing that the Faceless Assessing Officer has wasted his time in writing unsustainable order on objects. [S. 2(22)(e), 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Demerger-Notice not specifying failure to disclose any material facts truly and fully by assessee-Notice and subsequent order invalid. [S. 148, 263, Companies Act, 1956, S. 391 to394, Art. 226]
S. 144B : Faceless Assessment-Natural justice-Order passed without considering petitioners submission-Reasonable time not given to respond to show cause notice-Order and subsequent notices quashed-levied cost on the Assessing Officer Rs. 25,000 to be deposited to PM Cares Fund.[S.142(1), 143(3), 156, S.270A, 217AAC, Art. 226]
S. 144B : Faceless Assessment-Show cause notice was never served upon the petitioner-Natural justice-Personal hearing shall be issued at least seven working days in advance-Stricture-Harassment to assessee-Wasting precious judicial time and unnecessary expenditure on lawyers-The court held that the conduct of Assessing Officer was unacceptable and issuing of show cause notice cannot be just an empty formality. [S. 147,148, Art. 226]