S. 153A: Assessment-Search-Alleged unaccounted addition-Rejection of books of account-Order of the High Court deleting the addition is affirmed-SLP of revenue dismissed. [S.143(3), Art. 136]

S. 153 : Assessment-Reassessment-Limitation-Refund-Even assuming that, prior to amendment, no period of limitation was prescribed, any order now sought to be passed pursuant to directions of the Tribunal dated 03.04.2017 would be unreasonably delayed and barred by limitation. Refund of taxes with applicable interest as directed could not be faulted. [S. 92CA, 237, Art. 226]

S. 153: Assessment-Reassessment-Limitation-Order giving effect to the order of the Tribunal-Assessing Officer failed to give effect to the Tribunal’s directions for ten years-Time granted by the Single Judge for refund was to be extended by another eight weeks.[S,143(3), 254(1), Art. 226]

S. 153: Assessment-Reassessment-Limitation-High Court’s order merely laid down timelines for furnishing reasons and disposing of objections; it did not constitute a ‘finding or direction’ under section 153(6)(i)-Applying section 153(2), first proviso, read with the first proviso to Explanation 1 to section 153, reassessment was barred by limitation.[S.147, 148, 153(6)(i), Art. 226]

S. 149 : Reassessment-Time limit for notice-Sanction-Non-resident-Notice under section 148 was issued within three years; sanction under section 151 by PCIT was valid-Decision is pending consideration before Supreme Court, Jurisdictional Assessing Officer was competent to issue notices under sections 148A/148-[S. 10(4)(ii), 10(14), 10(15)(fa), 148, 148A(b), 148A(d), 151, 151A, 26AS, Art. 226,]

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, all notices issued on or after 1-4-2021 under sections 148 and 148A were liable to be dropped as they did not fall within the period prescribed under TOLA.[S. 147, 148, 148A(b), 148A(d), TOLA, Art. 226]

S. 149: Reassessment-Time limit for notice-Form of an asset had escaped assessment-All notices issued on or after 1-4-2021 would have to be dropped as they would not fall within the period prescribed under TOLA-Notice under section 148 and all consequential orders/notices, including recovery notices thereof, were quashed and set aside.[S. 148, 148A(b), 148A(d), Art.226]

S. 149 : Reassessment-Time limit for notice-First proviso to section 149(1) Acts as a restriction on retrospective application of extended ten-year limitation period-Reassessment notice under section 148 was issued in 2024 for assessment year 2013-14, but under erstwhile provisions (as extended by TOLA) time limit for issuance of such notice had already expired on 30-06-2021, by virtue of first proviso to section 149(1), revenue was barred from issuing notice under section 148 under new regime, notwithstanding ten-year period provided in section 149(1)(b) after its amendment by Finance Act, 2021.[S. 148,149(1)(b), TOLA, Art. 226]

S. 149 : Reassessment-Time limit for notice-Six years for relevant assessment year 2016-17, expired on 31-3-2022-SLP of revenue dismissed on account of delay of 411 days and also on merits. [S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Search-Notice was issued beyond the period of six years from the end of the relevant assessment year; said notice was barred by limitation in terms of the first proviso to section 149(1)-SLP dismissed. [S. 132, 148, 148A(b), 148A(d), Art. 136]