S. 153A : Assessment-Search or requisition-Long term capital gains on sale of shares-No incriminating material was found-Merely on the basis of statement of and letter of Managing Director of company-Addition cannot be made. [S. 10(38), 68]

S. 153A : Assessment-Search or requisition-Cash credit-Capital gain-Sale of shares-Incriminating material-When no incriminating material found during course of search and AO had made additions solely relying on disclosures made by Managing Director of a company on which search was conducted, impugned addition was unjustified. [S. 10(38), 45, 68]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Shares-SEBI registered broker-Information was not reported by the Assessing Officer of Vishesht Financial Services Pvt. Ltd. (VFSPL) to assessee’s Assessing Officer-Notice was set aside and matter was to be remanded to Assessing Officer to pass a fresh order-Matter remanded. [S. 69, 147, 148, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Survey-Bogus share capital-Share premium-Reopening notice issued on 20-7-2022-income alleged to have escaped more than Rs. 50 lakhs-Reopening notice was not time barred. [S. 68, 133A, 148, 149(1)(b), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Opportunity of hearing-Invested in penny scrips of two companies-A notice even if stated to be under section 148A(b) would be treated as a notice of enquiry under section 148A(a) if it contained questionnaire instead of information-Matter remanded. [S. 69, 148A(b), Art, 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Violation of principle of natural justice-Order passed without granting adequate time to fie reply-Order was set aside-Matter was to be remanded back to Assessing Officer for decision fresh. [S. 148, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Fake invoices-Input credit-Unexplained expenditure-Reassessment notice is held to be valid. [S. 69C, 143(3), 148, Art. 226]

S. 148 : Reassessment-Notice-Merger-Information about merger of company was intimated in original return of income filed-Notice issued in name of non-existing company-Reassessment notice was quashed. [S. 147, Art. 226]

S. 148 : Reassessment-Notice-Dead person-Notice issued for commencement of assessment or re-assessment proceedings against dead person is null and void. [S. 147, Art. 226]

S. 147 : Reassessment-Business expenditure-Increase in freight charges vis-a-vis purchases-Change of opinion-No new material-Reassessment is bad in law. [S. 37(1), 148]