S. 147 : Reassessment-After the expiry of four years-Losses-Capital gains-Losses carried forward-No failure to disclose material facts-Notice must specify facts which had not been disclosed-Notice not valid-SLP is granted to the Revenue. [S.72, 143(3), 148, Art. 136]

S. 144C : Reference to dispute resolution panel-Draft assessment order-Once objections have been filed by assessee against a draft assessment order within time limit prescribed under section 144C(2)(b), final assessment order should have been passed by Assessing Officer post receipt of direction from DRP-Matter remanded. [Art. 226]

S. 144C : Reference to dispute resolution panel-Draft assessment order-Objections against draft assessment order were filed-Copy of objections could not be placed before Assessing Officer-Assessment order was quashed and Assessing Officer is to be directed to await decision of DRP before issuing a fresh assessment order. [Art. 226]

S. 144C : Reference to dispute resolution panel-Draft assessment order-Filed objections to proposed variation only with DRP and a copy of same was not marked to AO-Objections filed with DRP would result in directions to AO-AO must complete assessment in light of directions as envisaged under section 144C(13).[S.144C(13),Art. 226]

S. 144C : Reference to dispute resolution panel-Draft assessment order-Passing of final order-Contrary to law-Mistake could not be cured-Notice is issued in SLP filed by the Revenue [S. 156, 292B, Art. 136]

S. 144B : Faceless Assessment-Principle of natural justice-Opportunity of hearing-Objections are not uploaded due to technical reasons-Order is set aside-Assessing Officer is directed to pass the order after direction from DRP.[S.144C(2), Art. 226]

S. 143(3) : Assessment-Assessment order without DIN (Document identification number) has not valid in law-Statutory defects in the assessment order cannot be cured by applying the provision of section 292B of the Act-Circular No 19 of 2019 dated 14-8-209 (2019) 416 ITR 140 (St) of CBDT is binding on the Revenue-Order of Tribunal quashing the assessment order was affirmed-On SLP, interim stay of order dated 20-3-2-2023 as well as order of the ITAT dated 19-9-2022, until further orders. [S. 144C, 147, 292B, Art. 136]

S. 142(2A) : Inquiry before assessment-Special audit-Extension of time-Cannot be exercised by the Commissioner-Order of Tribunal is affirmed.[S.142(2A)(C), 260A]

S. 139 : Return of income-Delay in filing return-Pendency of ruling before Authority for Advance Rulings (AAR)-Genuine hardship-Delay is condoned-Directed to pay cost of Rs 50000 each petition. [S.119(2)(b), 245R(2), Art. 226]

S. 139 : Return of income-Invalid return-Condonation of delay-Central Board of Direct Taxes-Genuine hardship should be construed in a liberal manner-Delay is directed to be condoned [S. 119(2)(b), 139(9) Art. 226]