S. 153A: Assessment-Search-Additions unsustainable in the absence of incriminating material for unabated assessments-No addition can be made-Order of Tribunal is affirmed. [S. 132, 133A, 153C, 260A]

S. 153 : Assessment-Reassessment-Limitation-When there is no finding or direction in terms of clause (i) of sub-section (6) of Section 153, the extended time shall be 60 days, as specified in the first proviso to Explanation 1 of Section 153, rather than 12 months-Direction-Inconsequence of-To give effect to-Finding-Assessment order is barred by limitation. [S. 143(3) 144B, 147, 148, 153(3)(ii), 153(6), 260,Income Tax Act, 1922, S. 34(3), Art. 226]

S.151A : Faceless assessment of income escaping assessment-Notices under section 148 must be issued in a faceless manner through automated allocation as per section 151A and the notification dated 29-3-2022. The Jurisdictional Assessing Officer (JAO) lacks the authority to issue such notices, rendering them illegal and invalid. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S.151A : Faceless assessment of income escaping assessment-Reassessment-Notice issued by Jurisdictional Assessing Officer instead of Faceless Officer held to be without jurisdiction [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 150: Assessment-Order on appeal-Conditions set out in S. 150 are required to be fulfilled for invoking S. 150 for issuance of notice under S. 148 beyond the period stipulated under S. 149-Appeal of Revenue is dismissed. [S. 148, 254(1), 260A]

S. 149 : Reassessment-Time limit for notice-Provisions of relevant assessment year applicable for reassessment proceedings. [S. 147 148,149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Incorrect premise-Reassessment notice based on incorrect assumption of non-filing of return-Held to be invalid-Order cannot be justified on basis of reasons supplied subsequently-DTAA-India-Mauritius [S. 9, 147,148, 148A(b), 148A(d), Art. 13(4), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-No opportunity of being heard-Violation of principles of natural justice-Reassessment notice u/s 148 and order u/s 148A(d) quashed [S. 148A(b), 148A(d), 149(1)(a), 149(1)(b)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-The interest income received from Non-Convertible Debentures (NCDs) was appropriately taxed under section 194LD, and could not be characterized as dividend liable for Dividend Distribution Tax (DDT) under section 115-O-Nexus between material relied on and formation of belief is necessary-Recorded reasons cannot be substituted-Notice and order disposing the objection is quashed. [S.115O, 147, 148, 148A(b), 148A(d), 194LD, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order is passed without giving assessee adequate opportunity to reply to the initial notice-Order is not valid-Matter is remanded back to the Assessing Officer. [S. 147, 148, 148A(b), 148A(d), Art. 226]