S. 147 : Reassessment-After the expiry of four years-Survey-Borrowed satisfaction-Reasons cannot be improved or supplemented-No failure to disclose material facts-Assessing Officer cannot rely on various case laws while disposing the objection without furnishing the copies or brining to the notice of the assessee-Notice of reassessment and order disposing the objection was set aside. [S. 133A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Revenue audit-Insurance business-Income from dividend from equity shares and interest from tax savings bonds-Reassessment notice and order disposing objection was quashed. [S. 10, 44, 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Mandatory-Failure to follow the procedure under Section 144C(1) of the Act would be a jurisdictional error and not merely procedural error or a mere irregularity-Order of assessment was quashed and set aside. [S. 292B, Art. 226]

S. 144C : Reference to dispute resolution panel-Remand proceedings-Draft assessment order has not been issued before the final assessment order is passed-The order set aside. [S. 92CA, 254(1), Art. 226]

S. 144B : Faceless Assessment-Natural justice-less than two days to reply-Personal hearing was not given-Stricture-The Assessing Officer could not care for the assessee and was not even conscious of what he was actually doing-This is a pure form of harassment of the assessee, a tax payer-The entire approach smacks of high handedness and don’t care attitude-Directed the Assessing Officer to pay a sum of Rs 25, 000 as cost from his salary /personal bank account to PM Care fund-The matter shall be placed before different from the Officer who had passed the impugned order dated 22-4 2021-Order was set aside for denovo consideration. [Art. 226]

S. 144B : Faceless Assessment-Natural justice-Draft Assessment order-Video Conferencing.-Request for personal hearing was not granted-Order was quashed and set aside-Directed to pass the order after granting personal hearing. [Art. 226]

S. 144B : Faceless Assessment-Natural Justice-Personal hearing not given-Order was quashed and set aside-Directed to grant personal hearing. [Art. 226]

S. 144B : Faceless Assessment-Natural justice-Personal hearing was not granted-Show cause-cum-draft Assessment order-Order was set aside. [Art. 226]

S. 144B : Faceless Assessment-Natural justice-Sufficient time was not given to petitioner to respond assessment order-Matter is remand to the stage when the draft assessment order was issued. [S. 147, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Tribunal decided the issue in favour of assessee in earlier years-Order of Tribunal binding on the Assessing Officer though the matter is pending for admission before High Court-Re assessment notice based on the order of earlier years is bad in law-Assessing Officer cannot rely on assessment orders which are non existing because these orders have been held unjustified by the ITAT. [S. 143(1), 148, Art. 226]