S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Opportunity of hearing-Order under section 148A(d)-Must be a speaking order-Failure to deal with assessee’s submissions renders order invalid. [S. 45, 148, 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Unsigned notice –Failure to file return-Writ petition held not maintainable for failure to follow procedure laid down in GKN Driveshafts case-Directed to file the return of income along with all objections, including the validity of the notice, before the Assessing Officer for disposal via a speaking order. [S. 139, Art. 226]

S. 148: Reassessment-Notice to non-existent entity-Amalgamation-Notice issued to an amalgamating company is invalid where the basis for reopening collapses. [S. 2(1B),147 292B, Art. 226]

S. 148 : Reassessment-Notice-Amalgamation-Non existing company-Notice to non-existent amalgamating company is fundamentally invalid-Error is not a mere procedural or clerical mistake that can be rectified under section 292B of the Income-tax Act, 1961. [S. 147, 292B, Art. 226]

S. 147: Reassessment-Within four years-Reason to believe-Intimation under S. 143(1)-Reopening notice based on a system-generated alert from the Non-Filer Management System (NMS) without independent application of mind is invalid. [S. 68,139, 143(1), 148, Art. 226]

S. 147: Reassessment-Change of opinion-Enquiry during original assessment-Where Assessing Officer has raised a specific query during original assessment proceedings to which the assessee has replied, the issue is deemed to have been examined-Reopening assessment on the very same issue, even if not discussed in the assessment order, constitutes an impermissible change of opinion. [S. 37(1), 142(1), 148, Art. 226]

S. 147 : Reassessment-Within four years-Change of opinion-Prior period expenditure-Order of tribunal quashing the reassessment is affirmed. [S. 37(1), 260A]

S. 147 : Reassessment-Reason to believe-Jurisdiction-Unexplained money-Notice based on fundamentally wrong facts pertaining to a different entity-Constitutes non-application of mind-Reopening invalid. [S 69A, 148, 151, Art. 226]

S. 147 : Reassessment-Charitable or religious trust –-Non-application of mind-Receipts from charitable activities mistaken for commercial income-Reopening notice based on mechanical reasoning and factual errors quashed. [S. 11, 143(1) 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years / Within four years-Reasons to believe-Reopening based on borrowed information from DRI or Justice M.B. Shah Commission Report without independent application of mind by AO is not permissible-Failure to disclose material facts cannot be alleged based on a subsequent Supreme Court ruling. [S. 148, Art. 226]