S. 147 : Reassessment-Date of issue and service of notice-Digital signature of Authority dated March 31, 2021-Notices Issued through Electronic mode on March 31, 2021 prior to amendment in law from April 1, 2021 and deemed to be served. [S. 148,149, 282, 282A, TOLA Act, 2020, S. 3(1), IT Rules 1962, R 127A(1), Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-Payment to related parties-Failure to deduct tax at source-Allowed claim without speaking order-Re assessment notice-Not valid. [S. 40A(2)(b), 148, 194C, Evidence Act, 1872 S. 114(e), Art. 226]

S. 147 : Reassessment-Writ-Territorial jurisdiction of High Court-Cause of action-Permanent Account Number Card having Cuttack address-Residential address in Ahmedabad-Amendment of Article 226 in 1976-The validity of the reassessment notice would not be considered by the Gujarat High Court. [S. 148, Code of Civil Procedure, 1908, 20(6), Art. 226(2)]

S. 147 : Reassessment-After the expiry of four years-Capital gains-Change of opinion-No failure to disclose material facts-Notice to with draw the exemption is held to be not valid. [S. 45, 54B, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Failure to disclose material facts-Limited scrutiny assessment-Subsequent information by investigation wing-Bogus transaction-Accommodation entries-Reassessment notice is valid. [S. 148, Art. 226]

S. 145A : Method of accounting-Valuation-Bank-Stock in trade-Valuation of unquoted securities-Order of Tribunal affirmed.

S. 144B : Faceless Assessment-The principles of law and other parameters as provided under the law for the purpose of assessment remain the same-Scheme has been introduced in order to keep pace with dynamics of the changed environment to march step by step towards making the systems efficient and transparent-Scheme of Faceless Assessment legal and valid. [S. 2(7A), 116, 143(3)) 144, Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-Unable to file objections due to lockdown-Existence of alternative remedy-Not bar to exercise of writ jurisdiction where principles of natural justice violated-Order and notice set aside. [S. 143(3), 156, 246A, 271AAC(1), 274, Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-Video conference not provided-Assessment order set aside. [S. 147, 155, Art. 226]

S. 144B : Faceless Assessment-Proposed variation in income-Failure to grant personal hearing-Order of assessment and notices of penalty and demand set aside-Matter remanded. [S. 143(3), 144B(7), 156, 270A, 271AAC, Art. 226]