S. 148A : Reassessment – Conducting inquiry, providing opportunity before issue of notice – Order passed under section 148A(d) is not a final adjudicating order but a preliminary order – Assesse is entitled to full opportunity to raise objections during the course of reassessment proceedings – Petition was dismissed as premature.[S. 148A(b), 148(a)(d), 149, Art, 226]

S. 148 : Reassessment -Notice – After the expiry of four years- Notifications issued by the Central Government under the Taxation and other laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not apply as the notices were issued prior to 1st April 2021- Time limit – Notices issued prior to 1st April 2021 beyond a period of four years from the expiry of the assessment year are time barred in terms of first proviso to section 147 as applicable prior to amendment made by the Finance Act, 2021- Sanction – Notice issued after seeking approval Jt. CIT instead of Chief CIT/ CIT Jt CIT instead of Chief CIT/ CIT- Notice was invalid. [S. 147, 151, Art, 226]

S. 147 : Reassessment – Change of opinion- Initiation of reassessment proceedings merely on the basis of change of opinion is invalid [S. 10(23G), 40(a),148, 260A]

S. 69 : Unexplained investments – Onus is on the assessee to explain the cash deposits and if no explanation is given, the amount can be assessed as assessee’s income. [S. 68, 260A ]

S. 68 : Cash credits – Firm – Capital account- Onus was on assessee firm to prove the capacity of the partners who introduced cash as capital in the assessee firm – Amendment brought by Finance Act, 2021 which requires establishment of ‘source of source’ is clarificatory in nature. [S. 260A]

S. 12AA : Cancellation of registration-Trust or institution-Survey-No incriminating material was found-Accommodation entries- Cancellation of registration without giving an opportunity of cross examination is not valid. [S. 12A, 133A]

S.147: Reassessment – After the expiry of four years – Valuation of equity shares – Share premium – Income from other sources – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed .[ S. 56(2) (viib), 148 , Art , 226 ]

S.147: Reassessment – After the expiry of four years – Loans and advances to sister concern – Allegation of colourable device – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed . [S. 69, 148 , Art , 226 ]

S. 292CC : Authorisation and assessment in case of search or requisition-Separately in the name of each person-Validity-Search was conducted after introduction of section 292CC and not by applying provision retrospectively-Amendment is clarificatory in nature-Challenge to constitutional validity of section 292CC was rejected. [S. 132,132A, Art. 226]

S. 264 : Commissioner-Revision of other orders-Withdrawal of application-Rejection of prayer for withdrawal of application-decided the application on merit-Directed the Commissioner to decide the application for withdrawal as expeditiously as possible. [Art. 226]