S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Income-Deemed to accrue or arise in India -Royalties/Fees for technical services DTAA -India-Singapore [S.9(1)(vi), 9(1)(vii), Art.12, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Capital gains- Assessing quantum of escaped income in matters like this, amount mentioned in registered conveyance couldnot be straight away taken as income escaping assessment without deducting cost of acquisition therefrom. Order of single judge was affirmed. [S. 45, 48, 147, 148, 148A(b), 148A(d), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Alternative remedy-High Court held that since Assessing Officer had passed well detailed order after rebutting assessee’s contentions, assessee should be directed to adopt alternate remedy of appeal against assessment order-SLP filed by assessee against the order of High Court was dismissed [S. 143(3), 148, 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice- Order of High Court set aside in view of UOI v. Rajeev Bansal [2024]301 Taxman 238/469 ITR 46(SC) final assessment order was quashed only for purpose of enabling assessee to raise all objections and contentions vis-a-vis impugned notices.[S. 148, 148A(b), 148A(d), Art. 136]

S. 148 : Reassessment-Notice-Non application of mind-Notice was quashed. [S. 135A,292B, Art. 226]

S. 148 : Reassessment-Notice -Dead person-Department had knowledge of demise of assessee -Not bind legal representative- Notice and order quashed.[S.147, 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment -Amalgamation-Notice issued to non-existent company- Order is non-est and void- SLP of revenue dismissed. [S. 147, Art. 136]

S. 147 : Reassessment -With in four years- Cash credits-Cash deposits-Demonetisation-Re assessment notice was held to be justified-Writ petition was dismissed. [S. 68, 148, Art. 226]

S. 147 : Reassessment -Cash credits-Reason to believe-Suspicious Transaction Report (STR) -Burden of proof-Tribunal could not have applied the principle enunciated by court in criminal case to discharge of burden of proof beyond reasonable doubt-Order of Tribunal set aside. [S. 68, 148, 260A]

S.147: Reassessment-After the expiry of four years-Sale promotion expenses incurred on doctor -Since there was no failure on part of assessee to disclose fully and truly all material facts necessary for assessment, reopening notice was quashed.[S. 143(3), 148, Art. 226]