S. 148 : Reassessment –Limitation-Issue and service of notice-effect from 1-4-2021-Faceless Assessment-Despatch in accordance with Section 13 of Information Technology Act, 2000 essential-Uploading of notices on My Account on E-Filing Portal not valid transmission-Notices sent as attachment through E-Mail designated addresses bearing jurisdictional Assessing Officer’s digital signature valid under section 282A of the Act-Ratio of UOI v. Ashish Agarwal (2022) 444 ITR 1 (SC). [S. 147, 148A, 149, 151, 282, 282A, Information Technology Act, 2000, S. 13, Art. 226]

S. 148 : Reassessment-Notice-Limitation-Notice issued beyond six years from the end of the assessment year barred by limitation-Proceedings and demand notice was quashed. [S. 147, Art. 226]

S. 148 : Reassessment –Notice-Limitation-Initial notice issued after period of six years stating wrong assessment Year-Corrigendum issued thereafter cannot cure a procedural irregularity-Order rejecting objections set aside. [S. 147, 149, 292B, Art. 226]

S. 148 : Reassessment –Notice-Reasons recorded after issue of notice-Order of High Court setting aside of reassessment proceedings is held to be proper. [S. 147, 292B, Art. 136]

S. 147 : Reassessment-Alternative remedy-Educational institution-Obligation to file return-Participated in the proceedings-Writ petition was dismissed. [S. 10(23C), 139(4A), 139(4C), 148, Art. 226]

S. 147 : Reassessment-Order disposing of objections-Must be speaking order-Order set aside-Matter remanded to the Assessing Officer to consider afresh. [S. 148, Art. 226]

S. 147 : Reassessment-Assessment order-Stay of demand-Assessing Officer was directed to dispose of stay application in accordance with law. [S. 144, 148, 156, 226, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Limitation-Business application showing E-Mail served at 5. Am on April 1, after the expiry of time-Notice and reassessment order barred by limitation-Notice and assessment order was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Employee benefit expenses-The successor officer had not come into possession of any other information to indicate escapement of income but merely relied upon the methodology adopted by the assessee to apprehend escapement of tax-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Loan-Associated enterprise-International transaction-No failure to disclose material facts-Notice not valid and objection disposing the objection was quashed. [S. 92C, 148, Art. 226]