S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accepting information furnished by assessee-Order for conducting further enquiry-Not valid. [S. 147, 148, 148A(b), 148 A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice – Limitation- Issue of notice under new regime not permissible if time barred under old regime-By virtue of TOLA, Assessing Officer had period of twenty-nine days limitation left on date of commencement of reassessment proceedings to issue a notice under section 148-Notice dated 30-7-2022 for Assessment Year 2013-14 issued beyond period of limitation – Order and consequential notices set aside. [S. 144, 144B, 147, 148, 148(A)(b), 148A(d), 149, TOLA, 2020, S 3(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation – Fresh notice issued as per Supreme Court directions in UOI v. Ashish Agarwal( 2022) 444 ITR 1 (SC))- Fresh notice following new procedure issued in correct name of assessee Reassessment proceedings not vitiated by incorrect name in original notice-Reassessment proceedings under fresh notice valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation – Fresh notice issued as per Supreme Court directions in UOI v. Ashish Agarwal( 2022) 444 ITR 1 (SC))- Fresh notice following new procedure issued in correct name of assessee Reassessment proceedings not vitiated by incorrect name in original notice-Reassessment proceedings under fresh notice valid- SLP of assessee dismissed.[S. 147, 148, 148A(b), 148A(d), Art. 136]

S. 147 : Reassessment-Search and seizure-Reassessment-Reassessment pursuant to search carried out prior to 1-4-2021-Orders quashed.[S. 132, 148, Art. 226]

S. 147 : Reassessment-Change of opinion – Notice based on assessment order of subsequent assessment year-Non-deduction of tax at source on payment made to non-resident, short and long term gains on share transactions- Provision for warranty – Deduction u/s 35(2AB )-No independent formation of opinion by Assessing Officer based on new material-Reassessment notice quashed and set aside. [S. 35(2AB), 148, Art. 226]

S. 147 : Reassessment – Survey-Non-resident-Permanent establishment Permanent agent- Dependant establishment-Attribution of profits – Reassessment notice was up held by the Tribunal – No substantial question of law – Appeal dismissed-Rejection of application for recall of the order was affirmed. [S. 148, 254(2), 260A, Art. 226]

S. 147 : Reassessment-Notice – Subject matter of appeal-Income which is subject matter of appeal, reference or revision – Reassessment notice is not valid [S. 11, 148, Art. 226]

S. 147 : Reassessment-Search and seizure-Reassessment-Assessment of third person-Notice opportunity of hearing not mandatory for issue of notice of reassessment pursuant to search-Satisfaction note is internal communication of Department not requiring document identification number-No provision requiring supply of copy of satisfaction note to assessee with notice for reopening assessment -Writ petition dismissed. [S. 132, 148, 153A, Art. 226]

S. 147 : Reassessment-Capital gains-Information from investigation unit – Penny stock – Borrowed satisfaction- Fishing inquiry not permissible-Notice quashed and set aside.[S. 10(38), 45, 148, Art. 226]