S.147: Reassessment —Long-term capital gains — Improvement cost on land – Examined by the Assessing Officer in original assessment proceedings – Notice for reassessment is held to be bad in law [ S.45 , 148 ]

S.147: Reassessment —Officer recording reasons and issuing notice must be the jurisdictional Assessing Officer — Reasons recorded by jurisdictional Assessing Officer – E. assessment Scheme – Notice issued by officer who did not have jurisdiction over assessee — Defect not curable- Notice and consequential proceedings and order invalid [ S.148 , 292B ]

S.147: Reassessment-After the expiry of four years- Financial transaction accepted as genuine during original assessment — Subsequent information from income-tax investigation wing that transaction was with name-Lender — No disclosure of true facts — Notice of reassessment is held to be valid- The Court also directed the assessee to pay cost of Rs. 1 lakhs to be paid to The Delhi High Court Advocates Welfare Trust with in within four weeks of the receipt of the [ S.148 Art , 226 ]

S.147: Reassessment — After the expiry of four years- No failure to disclose material facts – Form of return not requiring specification of persons mentioned in Section- Assessing Officer not examining the clauses – Reassessment notice is held to be not valid [ S.80IB(10)( e ) & (f) , 148,Art , 226 ]

S.147: Reassessment-After the expiry of four years- No failure to disclose material facts – Long term capital gains – Notice held to be not valid . [ S. 54, 148 Art , 226 ]

S.147: Reassessment-After the expiry of four years- Audit objection – Not accepted by the Assessing Officer –Borrowed satisfaction – No failure to disclose material facts – Notice is held to be bad in law [ S.148 , Art .226 ]

S.147: Reassessment-After the expiry of four years- Manufacture -Change of opinion- Based on the basis of commission issued – Held to be bad in law and impermissible. [ S .2(29BA) 131ID , 80IB ,148 , Central Excise Act, 1944 S.2(f) ]

S.147: Reassessment-After the expiry of four years- Primary facts disclosed — Assessing Officer not making appropriate calculation —Notice of reassessment issued without jurisdiction — Existence Of Alternate Remedy would not bar issue ow writ to quash notice [ S.14A , 148 Rule 8D ,Art , 226 ]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts – Merely because the Assessing Officer did not record such acceptance in the assessment order that would not be a ground to conclude that income had escaped assessment- Reassessment notice is held to be not Valid [ S. 36(1)(iii), 40(a)(ia), 148 ]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts – Reassessment order is held to be not valid. [ S.148 ]