S. 153 : Assessment-Limitation-Failure to pass the order within six months from the date of communication of the Tribunal order-Appellate Tribunal restored the matter to the file of AO with directions to comply with the same within 6 months-Assessment order passed beyond the stipulated timeline provided by the ITAT is barred by limitation.[S.153(3), 254(1) Art.226, 265]

S. 151 : Reassessment-Sanction for issue of notice-Mere use of expression Yes I am satisfied could not be considered to be a valid approval-Non application of mind-Reassessment notice is quashed. [S.143(1), 147, 148, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice –Recording of satisfaction-No mandate for the Pr. CIT to record his own reasons for approval or satisfaction-It would be sufficed that the Pr. CIT recorded the satisfaction regarding the reasons recorded by the AO-Writ petition is dismissed.[S. 148, Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice under section. 148A(b) is issued in the name of dead person-Notice and order is quashed-Even otherwise, since tax had already been deducted on salary income, as was evident from Form-16, reassessment action leading to demand of tax could not be initiated against assessee or even his legal representatives is not valid. [S. 15, 148, 148A(b), 1488A(d), 192, Form No 16, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Notice issue by jurisdictional AO and not by faceless AO-Bad in law hence quashed.[S. 148, 148A(b), 148A(d), 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Assessee had not initiated any legal proceedings to assail the notice dated 30.06.2021 issued under section 148-Subsequent notice issued under section 148A(b) pursuant to decision of Hon’ble Supreme Court in UOI v Ashish Agarwal (2022) 286 Taxman 183/ 444 ITR 1 (SC) is barred by limitation. [S. 148, 148A(b) 148A(d) 149, Art. 226]

S. 148A: Conducting inquiry, providing opportunity before issue of notice under section 148-decision of Hon’ble Supreme Court in the case of UOI v. Ashish Agarwal [2022] 444 ITR 1 (SC) does not mandate reopening of completed assessment.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Before passing order under S. 148A(d) the Officer ought to give a personal hearing if requested for by the assessee-Grant of approval by PCIT without application of mind to the form of approval-Order and notice liable to be set aside. [S. 148, 148A(b), 148A(d),149(1)(b), 151 Art. 226].

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by JAO in defiance of section 144B is bad in law. [S. 144B(7), 144B(8)_, 148, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Non-resident-Term deposits out of remittances from Dubai-Assessing Officer Vijayanagram had jurisdiction over assessee, notice issued by Assessing Officer, Vapi is in valid-Reassessment notice and order disposing the objection is quashed.[S.10(4)(ii), 148, 148A(b), 148A(d), Art. 226]