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]

S. 147 : Reassessment-After the expiry of four years-No failure to record reasons-Reasons offered at later stage cannot be considered-Notice and order disposing the objection is quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Notice based on report from Department of Revenue Intelligence-Shah Commission report-No independent application of mind By Assessing Officer-Based on subsequent decision of Supreme Court-Notice is not valid. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Neither reasons recorded nor order rejecting objections showing receipt chargeable to tax-Reassessment is held to be not valid-Capital gains-Transfer-Partner in firm-Bequeathed by father-Consent terms-Arbitration Award-Relinquishment of interest in partnership-Not transfer not liable to capital gains tax-Family arrangement-Not taxable-Onus on Department to establish certain receipt as income-Income from other sources-Firm continuing as going business with other partners-Receipts is not chargeable as income from other sources or as damages on dissolution of firm.[S. 2(24) 2(47) 45, 45(4), 56(2) 148]

S. 144C : Reference to dispute resolution panel-Faceless Assessment-Limitation-Penalty-Draft assessment order-Transfer Pricing Officer has no role after directions issued by Dispute Resolution Panel-Directions binding on Assessing Officer-Order is time-barred-Original return of income is directed to be accepted-Order and penalty notice set aside. [S. 92CA(4), 143(3), 144C(5), 144C(13), 156, 270A, 274, Art. 226]

S. 144B : Faceless Assessment-Principle of natural justice-Opportunity of personal hearing must be given even if not requested in writing-No discretion with Assessing Officer-Assessment order is set aside. [143(3), 144B(6)(vii), 144B(6)(viii), 251, Art.226]