S. 147: Reassessment-Unexplained money-Reassessment order making addition under section 69A was passed without granting personal hearing, and despite the assessee seeking adjournment on medical grounds, the portal was closed before reply could be filed; the order violated principles of natural justice and the matter was remanded for fresh adjudication-Directions to the Department to open portal subject to payment of Rs. 2,000 to hospital by assessee-Order to be passed after considering the assessee’s reply.[S.69A 144B,149 Art. 226]

S. 147: Reassessment-Information from Insight Portal-Allegation of accommodation entries-No independent inquiry conducted or evidence recorded to establish nexus with assessment records-Reasons recorded not sufficient to form bona fide belief of escapement of income-Reopening based on borrowed satisfaction and for fishing inquiry-Notice and consequential orders were quashed-Change of name and permanent account number not resulting in change of territorial jurisdiction-Assessing Officer before whom return had been filed earlier has jurisdiction to issue notice [S. 120, 124, 148,Art. 226]

S. 147: Reassessment-AO recorded reasons mechanically on information received from Investigation Wing / DCIT arising from search on third party-Reasons based on borrowed satisfaction and incorrect factual assumptions, evidencing non-application of mind-Reopening notice and consequential proceedings quashed. [S.148, S.151, Art. 226]

S. 147: Reassessment-Notice under section 148 invalid where original assessment was completed under section 143(3) after full disclosure and satisfaction of AO-AO lacked jurisdiction to reopen assessment in absence of fresh tangible material and amounted to mere change of opinion-Notice and order disposing objections were quashed and set aside-Reassessment cannot be sustained without new material. [S.115JB, S.143(3), S.148]

S. 147: Reassessment-Cash credits-Change in name-Territorial jurisdiction-Information on Insight portal-Held, mere change in name does not lead to change in jurisdiction-Held, no evidence relied on during recording of reasons-Reopening quashed-SLP dismissed. [S. 68, 124(1),148, Art. 136]

S.147: Reassessment-Audit objection-CSR expenditure-Reassessment proceedings initiated solely on audit objection, without independent application of mind by AO, are invalid-Reassessment proceedings quashed.[S. 37(1), 148, Companies Act 2013, S.135, Art. 136]

S. 147: Reassessment-AO recorded reasons mechanically on information received from Investigation Wing / DCIT arising from search on third party-Reasons based on borrowed satisfaction and incorrect factual assumptions, evidencing non-application of mind-Reopening notice and consequential proceedings quashed by High Court-SLP of revenue was dismissed. [S.148, S.151,Art. 136]

S. 147: Reassessment-AO lacked jurisdiction to reopen assessment in the absence of fresh tangible material and it amounted to a mere change of opinion-Notice and order disposing of objections were quashed and set aside by High Court-SLP of the revenue dismissed. [S.115JB, S.143(3), S.148, Art. 136]

S. 144C: Reference to dispute resolution panel-DRP directions and order without DIN number-Held, DRP directions and Order quashed-CBDT circular binding-Appeal dismissed. [S.119, 260A]

S. 144C: Reference to dispute resolution panel-DRP directions and order without DIN number-Held, DRP directions and Order quashed-CBDT circular binding-Appeal dismissed. [S. 119m, 114C(13), 260A]