S.147: Reassessment-After the expiry of four years-Capital asset –Agricultural land-Agricultural and situated beyond municipal limits, same did not come within ambit of section 2(14)(iii)(a)-No capital gain is liable to be taxed.[S. 2(14)(iii)(a), 45, 143(3), 144, 148, Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-G.P rate of unrecorded transactions were recorded at 7.5% as against G.P rate of 12.5 % in respected recorded transactions-Reassessment notice and order disposing the objection is quashed. [S.143(3), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Bogus bills-Accommodation entries-Book profit-Adding the amount calculated by Assessing Officer towards escaped income amount computed under ordinary provision of Act amounted would be less than the amount paid as per book profit-Notice and order disposing the objection is quashed. [S.115JB,143(3), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-notice under section 148 issued to examine the issue already verified during the course of assessment proceedings-No failure on the part of assessee-Notice is invalid.[S.28(i), 148, Art.226]

S.147: Reassessment-After the expiry of four years-Agricultural land-Capital gains-No new tangible materials or evidences-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S. 45, 54B,54F, 143(3), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Cash credits-Notice under section 148 issued relying on the information received from investigation wing without making any further inquiry-Notice is void ab initio.[S. 68, 148, Art.226]

S.147: Reassessment-After the expiry of four years-Business connection-Survey-Failure to deduct tax at source-Except for one, all other affiliates did not have a Permanent Establishment in India-Reassessment notice and order disposing the objection is quashed OECD Model Convention-Art. 5. [S.9(1)(i)),40(a(i), 133A, 148 195,201(1), Art. 226]

S.147: Reassessment-After the expiry of four years-Cash credits-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed and set aside.[S.68,147, Art.226]

S. 147 : Reassessment-After the expiry of four years-No failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment-Reopening of the completed assessment on the basis of same set of facts and on mere change of opinion based on an internal audit of the Revenue’s functioning held illegal and quashed-Sanction is given without application of mind-Reassessment is quashed. [S. 148, 151, Art. 226]

S. 144C : Reference to dispute resolution panel-Assessment Limitation-Assessment order is beyond limitation-Pending for final hearing-Assessment order passed under section 143(3) read with section 144C(3) and section 144B as also consequent demand notice and penalty proceedings were to remain stayed. [S. 143(3), 144B, 144C(3), Art. 226]