S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Expenditure prohibited by law-Amounts paid by Hospitals as referrals to Doctors-Not deductible-Interpretation of taxing statutes-Interpretation taking into account intention of legislature-Reassessment notice was quashed-Notice not valid. [S. 148, Art. 226]

S. 147 : Reassessment-With in four years-Share capital-Share premium-Income from other sources-Produced evidence in support of increase of authorised share capital, share allotment and names and address of parties from whom share premium received-Change of opinion-Reassessment order quashed by the High Court is affirmed. [S. 56 (2)(viib), 148, Art. 226]

S. 147 : Reassessment-With in four years-Specific queries raised by Assessing Officer and answered by assessee at time of original assessment-Change of opinion-Reassessment notice is not permissible. [S. 35D, 37(1), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Reassessment is bad in law. [S. 148, Art. 226]

S. 144B : Faceless Assessment-Assessment order passed without issuing notice-cum-draft assessment order-Violation of principles of natural justice-Alternate remedy not a bar to writ remedy-Assessment order and consequent demand notice and penalty proceedings set aside-Matter remanded to Assessing Officer. [144, 144B, 147, 156, 271(1)(c), Art. 226]

S. 143(3) : Assessment-Income from undisclosed sources-Finding of fact-No substantial question of law. [S. 132, 260A]

S. 143(3) : Assessment-High-Pitched Assessment-Strictures-Instructions of CBDT to be followed-Tax payers are one of the important pillars of the Country-Their harassment not only causes a jolt to the economy of the country and employment but also comes in the way of economic policy of the Government including the policy “ Ease of Doing business “-The instruction dated April 23, 2022 issued by the Central Board of Direct Taxes, needs to be implemented. Truly and effectively-Writ of mandamus issued to the CBDT with detailed directions. [S. 119, Art. 226]

S. 132B : Application of seized or requisitioned assets-Cash seized-Assessment quashed-Direction issued to dispose pending application expeditiously. [S. 132, 132B(4)(b), 244A, Art. 226]

S. 127 : Power to transfer cases-Order of transfer to facilitate investigation in to evasion of tax-Order of transfer is valid. [S. 124(1), Art. 226]

S. 127 : Power to transfer cases-Assessee aware of real reason for transfer of case-Natural justice-Public interest can justify Violation of principle of Audi Alteram Partem. [Art. 226]