S. 197 : Deduction at source-Certificate for lower rate-Mere assertion that income could not be estimated cannot be ground for rejection of application for certificate. [R.28AA, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Block Assessment-Satisfaction note-Block period-Seized material must pertain to relevant assessment year-Bearing-Notices issued in absence of incriminating material based on non-speaking satisfaction notes unsustainable-Satisfaction notes in these petitions had alluded to incriminating material having been recovered for the assessment years 2013-14 and 2014-15, respectively, and the materials that were correlatable had been specifically identified. All other contentions of parties could be raised in the ongoing proceedings. [S. 132, 153A 158BB, Art. 226 ]

S. 149 : Reassessment-Time limit for notice-Notices issued under unamended provision after 1-4-2021 for assessment year 2013-14-Notice is not barred by limitation.[S. 147, 148, Art. 226]

S. 149 : Reassessment-Time limit for notice-Finance Act, 2021-Search conducted in June, 2022-Relevant assessment year-Notice of reassessment on 31-3-2023 for Assessment Year 2013-14 is valid. [S. 149 153A, 153C, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessee must be given opportunity to be heard-Notice and order disposing the objection is quashed and set aside.[S. 148, 148A(b), 148A(d),Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Change of opinion-New procedure does not depart from principle that reassessment not permissible on mere change of opinion-Notice and order disposing the objection is quashed. [S. 147, 148, 148A(b), 148A(d) Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notice issued under existing law and reassessment order passed becoming final-Notice issued under section 148A pursuant of direction of Supreme Court in UOI v. Ashish Agarwal (2022) 444 ITR 1(SC)-Notice is without jurisdiction hence quashed. [S. 147, 148 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Opportunity of personal hearing requested in reply to Initial show-cause notice not given-Reassessment notice and order disposing the objection is quashed and set aside.[S 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sanction-Non application of mind-Discrepancy in quantum of escapement of income-Order and consequent notice is set aside. [S. 147, 148, 148A(b), 148A(d), 151, Art. 226]

S. 148 : Reassessment-Notice-Service of notice-Mandatory-Assessing Officer though aware of new address of assessee issuing notice at old address-No statutory obligation on assessee to update address in Permanent Account Number database-Participation in reassessment proceedings without service of notice does not validate notice and proceedings-Order of Tribunal quashing the assessment is affirmed. [S. 143(1), 147, 149(1)(b), 260A, 282(1), 292BB, Civil Procedure Code, 1908, Order V, rule 12]