S. 147 : Reassessment-Cash credits-Accommodation entries-Addition made on different grounds not forming part of reasons for reopening of assessment-Once principal grounds on which reassessment was proposed are dropped, no further additions can be made even by taking recourse to Explanation 3 to section 147-Order of Tribunal deleting the addition is affirmed. [S.68, 147, Expln. 3 148, 260A]

S. 147 : Reassessment-After the expiry of four years-Search and seizure-Original assessment made pursuant to search and seizure based on appraisal report and materials seized during search and seizure operations-Reassessment notice based on audit objection which was based upon same appraisal report-Notice not based on new material coming to notice of Assessing Officer-Not sustainable–Limitation Four to six years counted from end of assessment year Notice for assessment year 2014-2015 dated 31-3-2021 not barred by limitation–Reassessment-Notice after four years-Sanction of prescribed authority-Law before amendment with effect from 1-4-2021-Principal Commissioner competent to accord permission for reopening of assessments beyond four years-Assessing Officer digitally signing notice on 31-3-2021 at 7.01 p.m.-Notice goes beyond control of Assessing Officer at that moment Notice within prescribed time limit-Generation of document identification number by online portal on 1-4-2021 would not render notice barred by limitation. [S.132, 148, 149(1)(b), 151, Art.226] .

S.147: Reassessment-After the expiry of four years-Suspicion-Information received from Investigation Wing-No independent examination-Reassessment notice and order disposing the objection was quashed and set aside.[S. 148, Art. 226]

S.147: Reassessment-After six years-Search and seizure-Cash credits-Share application money-Failure to issue notice-Reassessment based on suspicion-Deletion of addition by Tribunal is affirmed. [S. 68,133(6), 148, 260A]

S. 147 : Reassessment-After the expiry of four years-Set off the losses incurred in one unit against the profits of the other unit-Audit objection-Change of opinion-Notice and consequential proceedings quashed-Circular No. 7/DV/2013 dated July 16, 2013 (2013) 356 ITR (St.) 7).[S.10A, 10AA, 148, 151]

S. 144B : Faceless Assessment-Personal hearing not granted-Matter remanded to Assessing Officer-Violation of principles of natural justice Assessee need not be relegated to statutory remedy of appeal.[S. 143(3), Art.14, 226]

S. 144B : Faceless Assessment-Assessment order passed without issuing show-cause notice-cum-draft assessment order-Assessment order and consequential demand notice and recovery proceedings set aside-Matter remanded to Assessing Officer-Violation of principles of natural justice Assessee need not be relegated to statutory remedy of appeal. [Art. 226]

S. 143(3): Assessment-Amalgamation-Assessment orders passed in names of amalgamating entities-Amalgamation approved by court was informed to Department with date and other details-assessment orders issued in names of non-existent entities void ab initio-Jurisdictional issue-Additional ground was raised first time before High Court-Additional ground was admitted-Interim applications allowed-Appeals by Revenue and assessee’s writ petition rendered infructuous.[S. 143(3), 254(1), 260A]

S. 143(3): Assessment-Amalgamation-Assessment framed and TPO order passed in the name of a non-existent amalgamating company despite intimation of merger-Subsequent attempt to rectify by invoking s.154 impermissible-Use of expression “formerly known as” shows failure to acknowledge change in legal status-Assessment order a nullity and not curable u/s 292B.[S.92CA(3), 154,260A, 292B]

S. 143(3): Assessment-Reassessment-Undisclosed income-Writ jurisdiction-Alternative remedy-Granted liberty to file statutory appeal.[S. 147, 148, 246A, Art. 226]