S. 151A: Faceless assessment of income escaping assessment-Reassessment-Jurisdictional Assessing Officer (JAO) as well as Faceless Assessing Officer (FAO) possess concurrent jurisdiction to initiate reassessment proceedings under section 148-Notice issued by JAO is valid and not in contravention of the statutory scheme under section 151A. [S. 147, 148 Art. 226]

S. 151: Reassessment-Sanction for issue of notice-Cash credits-Share capital and share premium received-Accommodation entries-Reopening of assessment-Approval under section 151-Single line approval recording satisfaction held valid-Competent Authority used language ‘Yes, I am convinced it is a fit case for reopening of assessment under section 147 by issuing notice under section 148’, same would satisfy the mandate of section 151-ITAT order quashing reassessment set aside low tax effect-Exception. [S. 68, 147, 148, 268A]

S. 149: Reassessment-Time limit for notice-Notice issued under section 148, pursuant to an order passed under section 148A(d), beyond the prescribed statutory period of 30 days was bad in law. [S. 148, 148A(b), 148A(d), TOLA S. 3, Art. 226]

S. 148: Reassessment-Reason to believe-Information/material indicating escapement of income-Purchase of flat from builder does not by itself bar reassessment-S. 148 as applicable from 1-4-2021 [Art. 226]

S. 147: Reassessment-Disallowance of expenditure-Exempt income-Assessee participated in proceedings and objections disposed of by a speaking order-Writ petition challenging notice under section 148 not maintainable at show-cause stage-Order of single judge set aside. [S.14A, 148, Art. 226]

S. 147: Reassessment-Reason to believe-Order of Transfer Pricing Officer for subsequent assessment year can be taken into account for reassessment of period prior to amendment of section 92-Writ petitions dismissed. [S. 92, Art.226]

S. 147: Reassessment-Reassessment order passed in reliance on a superior court ruling after original notices were quashed by the High Court-An unappealed High Court judgment quashing a notice remains final and cannot be bypassed via subsequent universal rulings. [S. 148, 148A(b), 148A(d), 149, Art. 226]

S. 144C: Reference to dispute resolution panel-Reference to TPO under section 92CA was made on 11-01-2022 after expiry of limitation for passing an assessment order under section 153(2) on 31-03-2021; it was without jurisdiction. The order passed under section 92CA (3) on 27-01-2022 and consequential proceedings under section 144C were set aside. [S. 92CA (3), 153(2), Art. 226]

S. 144C: Reference to dispute resolution panel-Transfer pricing-Assessment-Limitation-Remand by Tribunal directly to Transfer Pricing Officer-Second reference by Assessing Officer after Transfer Pricing Officer had already passed order in compliance with Tribunal’s directions-Superfluous and barred by limitation-Assessing Officer deprived of jurisdiction to pass final assessment order. [S. 92CA,, 153(3), 153(4), Art. 226]

S. 144B: Faceless assessment-Objections to draft assessment order-Filed before jurisdictional Assessing Officer instead of Faceless Assessing Officer due to inadvertence-Final assessment order quashed-Matter remanded to Dispute Resolution Panel. [S. 143(3), 144C, Art. 226]