S. 151 : Reassessment-Sanction for issue of notice-Amount involved is more than Rs. 50 lakhs-Approval has to be obtained from Principal Chief Commissioner or Chief Commissioner as defined under section 151(ii)-Approval was obtained from Principal Commissioner in terms of section 151(i) and no approval was obtained before issuance of reopening notice in terms of provision of section 151(ii)-Reopening notice was quashed and set aside. [S. 148,149, 151(1), 151(ii), Art. 226]

S. 149 : Reassessment-Time limit for notice-Since only one day was available for issuance of notice, after giving opportunity of filing reply to assessee-Last date to issue notice as per judgment of Supreme Court in Rajeev Bansal would be 12-6-2022-Notice under section 148 was issued on 15-7-2022-Notice dated 30-6-2021 was an invalid notice Notice dated 15-7-2022 as well as notice dated 30-6-2021was quashed and set aside. [S. 148,148A(b), 148A(d), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). S.3, Art. 226]

S. 149 : Reassessment-Time limit for notice-Old regime-Notice dt 23-7 2022 seeking to reopen assessment for assessment year 2015-16-Following UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC) all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under TOLA-Accordingly the notice and proceedings are quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-Old regime-dated 1-6-2021 seeking to reopen assessment for assessment year 2015-16-Following UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC) all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under TOLA-Accordingly the notice and proceedings are quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-Long term capital gains from equities-Amount was below threshold limit of Rs. 50 lakhs-Notice was issued beyond period of limitation as prescribed under section 149(1)(a) and conditions as specified so as to attract provisions of section 149(1)(b) were not satisfied, same was set aside. [S. 148, 148A(b), 148A(d), 149(1)(a), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained expenditure-Bogus purcahses-Information received from GST department-Disregarding response furnished by assessee solely for reason of information on portal and simply reiterating information as available, would render procedure under section 148A meaningless-Accordingly reopening notice issued against assessee was set aside [S. 69C, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-No reason was given in support of conclusion that escaped income was more than Rs. 50 lakhs-Matter was to be remanded back to Assessing Officer to decide same afresh in accordance with law.[S. 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Writ against issue of notice under section 148 was dismissed-Assessee filed SLP against order of High Court-Assessee sought permission to withdraw SLP with liberty to file review before High Court-SLP filed against order was to be dismissed as withdrawn with liberty to file review before High Court.[S. 131(IA), 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Capital gains-Full value of consideration-Stamp valuation-Non application of mind-Notice and consequential order was quashed by High Court-Delay of 331 days-SLP of revenue was dismissed as th delay has not been satisfactorily explained. [S. 50C, 148, 148A(b), 148A(d), Art. 136]

S. 148 : Reassessment-Notice-Notice through his Chartered Accountant-No notice was issued within period of limitation-Service of notice to Chartered Accountant was not valid service of notice-High Court quashed the reassessment notice-SLP delay of 327 days-Explanation rendered for delay was not satisfactory, SLP was dismissed on ground of delay and laches. [S. 149(1)(b), Art. 136]