S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Interest on bonds/Debentures-Interest income received on NCDs is in nature of dividend-liable to be taxed in terms of section 115-O-Reassessment notice and order disposing the objection is quashed-DTAA-India-Luxemborg [S.9(1)(v), 115-O, 148, 148A(b), 148A(d), 194LD, Art. 11, Art. 226.]

S. 147 : Reassessment-With in four years-Cash credits-Shell Companies-Information from Investigation Wing-Recorded reason mechanical manner without application of mind by the Assessing Officer-Mistake-A mistake, which can be corrected under section 292B, should be such that if excised it does not change tenor and scope of documents/proceedings referred to therein-Order of Tribunal quashing the reassessment order is affirmed-No substantial question of law.[S. 68, 143(1), 148, 260A, 292B]

S.147: Reassessment-After the expiry of four years-Unexplained expenditure-Prior period items and advertisement expenses-No new tangible material-Quashing of reassessment by the Tribunal is affirmed. [S.69C, 148, 260A]

S.147: Reassessment-After the expiry of four years-Industrial undertakings-Infrastructure development-Manufacturing and cut of polished diamond on job work basis and trading of diamonds and power generation through windmill-Amalgamation-No failure to disclose material facts-reassessment notice and order disposing the objection is quashed and set aside. [S.80IA(4)(iv) 143(3), 148, Form No.10CCB, Art. 226]

S.147: Reassessment-After the expiry of four years-Capital gains-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S. 48, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Income from other sources-Interest income-Credit for Tax deducted at source-Change of opinion-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S. 56, 143(3), 148, Art. 226]

S. 147: Reassessment-After the expiry of four years-Depreciation-Foreign exchange fluctuations on imported machinery-Project development-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S. 32, 115JB, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Unexplained money-Information from the ADIT (Investigation)-Purchases and sale of commodities through National Multi-Commodities Exchange (NMCE platform)-Borrowed satisfaction-Not valid in the eyes of law-Non application of mind-Reassessment notice and order disposing the objection is quashed.[S. 69A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Development agreement-Capital gain tax-Granted a licence to developer-Issue was consideration before the Assessing Officer-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed.[S. 2(47)(v), 45, 148, Transfer of Property Act, 1882, S.53A, Art. 226]

S. 147 : Reassessment-Special category states-Assessing Officer applied his mind-Proceeding to reopen assessment was actuated merely by a change of opinion and, hence, impugned notice was set aside-Time limit to issue of notice-Sanction obtained satisfaction of Additional Commissioner, an authority who is not covered by provision of section 151(1), as it stood on 1-1-2019, proceeding initiated against assessee-Issuance of notice under section 148 is held to be not in accordance with law-SLP of Revenue is dismissed on account of gross delay of 294 days. Revenue could not explain the delay satisfactorily.[S. 80IC, 148, 149, 151(1), Art.136]