S.151A : Faceless assessment of income escaping assessment-Reassessment-Notice issued by jurisdictional Assessing Officer and not as per S. 151A-Office Memorandum dt. 20th Feb., 2023 being F. No. 370153/7/2023-TPL issued by the CBDT has clarified that the JAO as well as units under NFAC have concurrent jurisdiction-Notice under S. 148 is not invalid on the ground that the same has been issued by the JAO and not by National Faceless Assessment Centre as per S. 151A. [S. 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Case covered by the provisions of S. 132A-Application under Section 451 of Cr.P.C.-Requisitioned from Police Station-Procedure contemplated by the provisions of s. 148A need not be complied with before issuing notices under S. 148.[S.132, 132A, 148, 148A(b), 148A(d), Cr.P.C.S. 451, Art. 226,]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-After four years – Limitation-Applicability of fifth proviso-Fifth proviso can only apply where one has to determine whether the time-limit of three years and ten years in S 149(1) are breached-Sixth proviso to S. 149 has no impact as it only provides a situation where after exclusion of the time period referred to in the fifth proviso, the time available with the AO for passing an order under S. 148A(d) is less than 7 days, then the remaining time frame shall be extended to 7 days and limitation also stands extended by 7 days-Revenue is seeking to exclude a period from 21st May, 2021 to 4th May, 2022-Which cannot apply-Hence, the notice dt. 31st July, 2022 is is barred by limitation hence bad in law. [S. 148, 148A(b), 148A(d), 149(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information from the insight portal-Disputed question of fact-Writ petition is affirmed. [S. 148, 148A(b) 148A(d), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information from the insight portal-Disputed question of fact-Order of single judge dismissing the writ petition is affirmed. [S. 148, 148A(b) 148A(d), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice in the name of deceased-Participated in the proceedings-Petition is dismissed on the ground that notice under S. 148A(b) was not in their names, subsequent orders and notice under S. 148A(b) and 148, respectively, cannot be passed and issued to them-The petitioners are granted 30 days further time from today to file return in pursuance to the notice under S. 148. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Second notice under section 148 was issued after first reassessment proceedings are finalized-No writ petition was filed against the original reassessment notice-Second reassessment proceeding is quashed.[S. 148, 148A(b), 148A(d), Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-Specific query was raised in the original assessment proceedings-Shares at premium-Borrowed satisfaction-Reassessment notice and order disposing the objection is quashed and set aside. [S. 68, 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Assessment-Limitation-Order passed beyond one month of directions of DRP under S. 144C(13)-The assessment order was barred by limitation.[S. 143(3), 144C(13), Art. 226]

S. 144B : Faceless Assessment-Opportunity of hearing-Principle of natural justice-Opportunity of personal hearing was not given-Writ petition is dismissed. [Art. 226]