S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by jurisdictional AO and not as per S. 151A— Section 144B cannot be viewed as exclusive basis for all assessment and reassessment procedures and Jurisdictional Assessing Officer (JAO) cannot be completely deprived of power to assess or reassess merely because section 144B and Faceless Reassessment Scheme 2022 have been introduced S.151A-Notice issued by Jurisdictional Assessing Officer-Guidelines issued in terms of sub-S. (2) of s. 144B will not amount to the directions issued by the Central Government in terms of sub(2) of s. 151A—Writ petition is dismissed. [S. 124 143(2), 144B,148, 148A]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Final assessment order passed by AO is quashed only for the purpose of enabling the assessee to take up all objections and contentions vis-a-vis the impugned notices-On SLP the Court held that the concerned AO shall consider the objections and contentions of the assessee. [S. 148, 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice in the name of dead person-High Court by an order disposed of writ petition reserving all contentions to be taken by legal heirs of assessee before Assessing Officer except contention that initial notice under section 148A(b) was issued to a dead person-Order of High Court is modified and the AO is directed to consider all legal arguments including defect notice issued in the name of dead person. [S. 148A(b), 148A(d), Art. 136]

S.148:Reassessment—Deceased-Insolvency proceedings— Once the assets were taken over by the Official Assignee and the assessee was declared as an insolvent, the respondents can very well approach the Official Assignee for seeking their remedy—It is upto the Official Assignee to consider the claims and distribute the proceeds in accordance with law. [S. 147,152(2), 226(3), 263, Art. 226]

S. 147 : Reassessment-Commission-Non-Resident-Commission paid to services rendered out side India-Commission for the services rendered outside India, were not chargeable and consequently, the returns were accepted— The contention of the Department that they sought to invoke the proceedings to rectify the mistake, has no merit-Writ petition is allowed. [S. 9(1)(i), 143(3), 148, 195, Art. 226]

S. 147 : Reassessment-With in four years-No new tangible material-Review is not possible-Reassessment notice and order disposing the objection is quashed. [S. 13(1)(d)(iia), 115BBC, 143(3), 148, Art. 226]

S. 147 : Reassessment-Income of any other person-Search-Penny stock-Capital gains-Shell companies-Cash credits-Non obstante clause-Information from Investigation Wing and also in the course of search-Reassessment is valid-Matter remanded to the Tribunal to decide other grounds. [S.68,132, 132A, 148,153A, 153C, 260A]

S. 143(3): Assessment-Jurisdiction of AO-Best judgement-Order passed without complying the provision of section 127 is quashed and set aside. [S. 120, 127, 144,260A, Art. 226]

S. 132(8) : Search and seizure-Retention of the books of account and other documents-Authorities are directed to return the books of accounts and other documents forthwith.[S. 132,132(9B), Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Return—Condonation of delay—Genuine hardship—Audit report was made available on 9th Sept., 2019 i.e., 5 months prior to the COVID outbreak— No reasonable cause-Rejection of application is up held-Writ petition is dismissed. [S. 119(2)(b), 139, 234F, Art. 226]