S. 151 : Reassessment-Sanction for issue of notice-Application of mind by sanctioning authority-Notice valid. [S. 147, 148, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Issuing third notice and furnishing specific details of transaction which was subject matter of earlier notice-Failure to explain or substantiate genuineness of transaction in reply-Notice and order for issuance of reassessment notice valid. [S. 147, 148, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Bogus entities-Vague show cause notice-Matter remanded to issue supplementary notice furnishing details. [S. 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-High-Pitched Assessments-Violation of principle of natural justice-Non application of mind-Gross negligence-Order was quashed-The action taken by the Department in terms of the instructions read with the affidavit referred to in the court’s order dated May 19, 2022 was to be communicated to the assessee by the Department and a compliance report was to be submitted before the court. [S. 147, 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Transactions of purchase and sale of shares-Notice under Section 148A(d) issued on different ground as reasons in 148A(b)-If Foundational allegation is missing in the notice issued under Section 148A(b)-Same cannot be incorporated by Issuing supplementary notice-Notice was quashed. [S. 147, 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Recording satisfaction with signature of prescribed authority mandatory-Prescribed Authority’s digitally signed approval obtained after issue of notice without jurisdiction and invalid-Notice and subsequent reassessment proceedings quashed. [S. 147 151, 282A, General Clauses Act, 1897, S. 3(56), Art. 226]

S. 148 : Reassessment-Notice-Law laid down by Supreme Court not followed-Matter remanded to Assessing Officer. [S. 147, Art. 226]

S. 148 : Reassessment-Notice-Notice should be issued by Assessing Officer who has jurisdiction over assessee. [S. 129, 147, 148(1), 148(2), Art. 226]

S. 147 : Reassessment-Notice-Reasons recorded unfounded-No failure to disclose material facts-Violation of principle of natural justice-Notice without jurisdiction-Strictures-Reassessment done without adhering to the rule of law-Illegal demand and order quashed-Cost of 50,00,000 was awarded on Department-Government to frame Circular-Alternative remedy is not a bar to maintain writ petition. [S. 144B, 148, Art. 226]

S. 147 : Reassessment-Notice-Best judgment assessment-Capital gains-Reasons recorded non-existent-Notice and subsequent reassessment order quashed. [S. 45, 144, 144B, 148, Art. 226]