S. 147 : Reassessment-After the expiry of four years-Amalgamation-Carry forward and set off of accumulated loss and unabsorbed depreciation-No failure to disclose any material fact-Change of opinion-Reassessment notice and order disposing the objection was quashed. [S. 72A(2), 72(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Infrastructure development-Change of opinion-Pendency of appeal before CIT(A)-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed.[S. 80IA, 148,246A, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Share capital-Share premium-No failure to disclose material facts-Reasons not specifying material facts which are not disclosed-Notice and order disposing the objection was quashed and set aside. [S. 68, 132, 147, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Business expenditure-Penalty imposed for breach of a civil obligation would be outside purview of Explanation 1 to section 37(1)-Assessing Officer who had specifically gone into the allowability of the claim-A mere assertion in the absence of any material would not constitute a ‘tangible material’ for purposes of reopening an assessment-Reassessment notice and order disposing the objection was quashed. [S. 37(1), 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-CSR expenditure-Prior period gain /loss-No failure to disclose material facts-Provision of Explanation 2 to section 37(1) inserted with effect from 1st April 2015 operates prospectively, from assessment year 2015-16-Reassessent notice and order disposing the objection was quashed. [S. 37 (1), 148 Art, 226, Companies Act, 2013, S. 135]

S. 147 : Reassessment-Residential Status-Resident or non-resident-Service of notice on chartered Accountant-Reassessment notice was held to be valid-Interest-Levy of interest-Automatic-Working in ITNS 150 forming part of assessment order was proper-Sikkim-Commission-Burden not discharged-Round tripping of funds-Liable to tax in India-Review petition is dismissed. [S. 2(35), 5, 6(3)(ii), 131, 142(1), 143(2), 148, 234A, 282]

S. 147 : Reassessment-After the expiry of four years-Amount payable to sundry creditors-Cessation of liability-No new information-SLP of Revenue is dismissed. [S. 41(1), 148, Art. 226]

S. 145 : Method of accounting-Deduction of tax at source-Tax deducted is income received-Running bills-AO was not justified in making addition on account of difference in payment received as per Form 26AS and books of accounts without verifying total contract amount and relevant bills. [S. 198, Form No. 26AS]

S. 144B : Faceless Assessment-Natural justice-Specific request to afford an opportunity of personal hearing through video conference-Order is set aside. [S.144B(6)(viii), Art. 226]

S. 144B : Faceless Assessment-Unexplained investments-Reassessment-Personal hearing was not provided-Assessing Officer was to be directed to grant personal hearing and pass assessment order on merits by taking appropriate facts. [S. 69, 147, 148, Art. 226]