S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-High-Pitched Assessments-Violation of principle of natural justice-Non application of mind-Gross negligence-Order was quashed-The action taken by the Department in terms of the instructions read with the affidavit referred to in the court’s order dated May 19, 2022 was to be communicated to the assessee by the Department and a compliance report was to be submitted before the court. [S. 147, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Transactions of purchase and sale of shares-Notice under Section 148A(d) issued on different ground as reasons in 148A(b)-If Foundational allegation is missing in the notice issued under Section 148A(b)-Same cannot be incorporated by Issuing supplementary notice-Notice was quashed. [S. 147, 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Recording satisfaction with signature of prescribed authority mandatory-Prescribed Authority’s digitally signed approval obtained after issue of notice without jurisdiction and invalid-Notice and subsequent reassessment proceedings quashed. [S. 147 151, 282A, General Clauses Act, 1897, S. 3(56), Art. 226]

S. 148 : Reassessment-Notice-Law laid down by Supreme Court not followed-Matter remanded to Assessing Officer. [S. 147, Art. 226]

S. 148 : Reassessment-Notice-Notice should be issued by Assessing Officer who has jurisdiction over assessee. [S. 129, 147, 148(1), 148(2), Art. 226]

S. 147 : Reassessment-Notice-Reasons recorded unfounded-No failure to disclose material facts-Violation of principle of natural justice-Notice without jurisdiction-Strictures-Reassessment done without adhering to the rule of law-Illegal demand and order quashed-Cost of 50,00,000 was awarded on Department-Government to frame Circular-Alternative remedy is not a bar to maintain writ petition. [S. 144B, 148, Art. 226]

S. 147 : Reassessment-Notice-Best judgment assessment-Capital gains-Reasons recorded non-existent-Notice and subsequent reassessment order quashed. [S. 45, 144, 144B, 148, Art. 226]

S. 147 : Reassessment-Addition made on the basis of for reopening assessment was deleted by CIT(A)-Other income cannot be assessed on the basis of invalid notice. [S. 148]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Shares received as gift and their value disclosed in original assessment-Reassessment notice is not valid. [S. 52(vii)(b), 148, Art. 226]

S. 145 : Method of accounting-Rejection of accounts-Estimate should be fair-Local knowledge and circumstances of assessee should be taken into consideration-Order of Tribunal affirmed. [S. 145(3), 260A]