S. 147 : Reassessment-Reasons recorded mere repetition of report of deputy director (Inv)-Failure to supply documents which were basis for formation of belief-Reassessment order and consequential notice of demand set aside. [S. 133A, 143(3), 148, 156, Art. 226]

S. 147 : Reassessment-With in four years and beyond four years-Audit objection-Depreciation-Assessing Officer rejecting audit objection-Existence of alternate remedy is not an absolute bar for issue of writ-Notice based on audit objection is held to be not valid. [S. 32, 148, Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-capital gains-Expenditure incurred in terms of settlement to assessee’s sisters from sale consideration of property and indexation benefits and other legal expenses-No failure to disclose material facts-Order disposing objection and notice for reopening was quashed and set aside. [S. 45, 48, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Based on audit report-Change of opinion-No new material-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Land taxes-Leave encashment-Gratuity-Demerger-No failure to disclose material facts-Order disposing objection and notice of reassessment was quashed. [S. 43B, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Provision for customs duty, advance doubtful of recovery and provisions of non-moving inventory-Notice and order rejecting objections was quashed. [S. 115JB, 148, Art. 226]

S. 147 : Reassessment-Rectification of mistake-Notice for reopening assessment not permissible during pendency of proceedings for rectification-Reassessment proceedings not sustainable-Order of High Court set aside. [S. 80HHC, 148, 154(7)]

S. 144B : Faceless Assessment-Principle of natural justice-Violation of statutory condition-Assessment order set aside-liberty to proceed in accordance with law granted after issuing show-cause notice-cum draft assessment order. [S. 143(3), 144B(1)(xvi)(b), Art. 226]

S. 144B : Faceless Assessment-Natural justice-Failure to follow mandatory procedure-Alternative remedy-Writ can be entertained-The assessment order and the notice of demand was quashed and set aside-The matter was remanded to the Assessing Officer who shall issue a show-cause notice along with the draft assessment order granting an opportunity of personal hearing to the assessee as prescribed under section 144B. Matter remanded. [S. 143(3), 144, 144B(1)(xvi)(b), 147, 156, Art. 226]

S. 144B : Faceless Assessment-Natural justice-Effect from 1-4-2021-Objection to draft assessment order must be considered-Order passed without considering objections is held to be not valid. [S. 144B(7), 144B(1)(xii), Art. 226]