S. 151 : Reassessment-Sanction-After the expiry of four years-Sanction was granted by Addl. CIT and not PCIT-Reference contained another entity-Non application of mind-Order was quashed and set a side. [S. 148, 151, Art. 226]

S. 150 : Assessment-Order on appeal-Time limit for reopening of assessment-Deemed dividend-Section 150 will apply only to reopening assessment to give effect to finding or direction in appellate orders of CIT(A) and not to appellate orders of any High Court u/s. 260A. [S. 2(22)(e), 116, 147, 148, 149, Art. 226]

S. 148 : Reassessment-Notice-Notice was issued prior approval of Additional Commissioner-Notice was quashed. [S. 147, 151(2), Art. 226]

S. 147 : Reassessment-Within period of four years-Change of opinion-Foreign remittance-Failure to deduct tax at source-No failure to disclose material facts-Issue was considered in the original assessment proceedings-Not specifically dealt in the assessment order-Reassessment notice was quashed. [S. 14, 40(a)(i), 90, 91, 92CA(3), 143(3), 148, 195, Art. 226]

S. 147 : Reassessment-With in four years-No new tangible material-Reason recorded and reasons stated in objections disposing the objection are different-Reassessment notice was quashed. [S. 2(47), 47(iv), 47A, 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Survey-No failure to disclose material facts-Information from DDIT-Borrowed satisfaction-Documents of report relied on must be furnished along with recorded reasons-Principle of natural justice-Judgements relied on without bringing notice to the assessee-Reasons cannot be improved or supplemented-Reassessment notice was quashed [S. 133A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Leave and licence agreement-Income from house property-Developing and running shopping mall-Income from business-No failure to disclose any material facts-Change of opinion-Notice issued by succeeding Assessing Officer-Notice was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Transfer pricing-Notice stating that fact had not been disclosed-Mere statement that there had been failure to disclose material facts is not sufficient-Reassessment notice on the basis of change of opinion was quashed. [S. 92CA(3), 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Set off of unabsorbed depreciation or business loss-Book profit- No new Tangible material-Notice and order rejecting objection raised by Assessee was set aside. [S. 115JB, 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-The documents and submissions which were available before the AO, before passing of the original assessment order;-Not even a whisper as to what was not disclosed-Reassessment notice was quashed. [S. 148 Art, 226]