S. 148 : Reassessment-Notice-Pendency of assessment-Time limit for issue of notice u/s. 143(2) was not expired-Notice issued for reassessment was quashed. [S. 143(1)(a), 143(2), 143(3), 147]
S. 148 : Reassessment-Notice-Pendency of assessment-Time limit for issue of notice u/s. 143(2) was not expired-Notice issued for reassessment was quashed. [S. 143(1)(a), 143(2), 143(3), 147]
S. 148 : Reassessment-Notice-Constitutional validity-The delegation authorized being only for the purpose of enlarging limitation under a valid law, such delegation could not be exercised to resurrect the provision of law that stood omitted from the statute book by virtue of its substitution made by the Finance Act, 2021, w.e.f. 01.04.2021-Directions issued. [Art. 226]
S. 147 : Reassessment-With in four years-Change of opinion-No tangible material-Not valid. [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Notice was quashed. [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Penny stock-No failure to disclose material facts-Reassessment notice was held to be not valid. [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Depreciation-Technical error by Auditor-Notice to withdraw the depreciation was held to be not valid. [S. 32, 148, Form No 3CD, Art. 226]
S. 147 : Reassessment-After the expiry of four years-No tangible material-Non-Resident-Not offering the interest and bonus received on surrender of policy before maturity-Provision of Section 80CC(2) is not applicable-Reassessment was quashed [S. 10(10)(d), 80CC(2), 143(1), 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Fabricated bogus documents-After disposal of objection the assessee participated in the proceedings-Sanction was issued within few hours of receiving information cannot be held to be non application of mind-Reassessment proceedings was held to be valid. [S. 69A, 143(3), 148, 151, Art. 226]
S. 145 : Method of accounting-Construction business-Change of method from project completion method to percentage completion method-Revenue neutral-Revised Accounting Standard 7-Held to be valid.
S. 145 : Method of accounting-Rejection of books of account-Bogus purchases-Order of Tribunal modifying the quantum was set aside-Cost of Rs.5000 was imposed on the assessee. [S. 145(3)]