S. 153A : Assessment-Search or requisition-Finality of assessment-No incriminating material-No abatement of concluded proceedings-Notice is issued in SLP filed by the Revenue. [S. 132, 143(3)]

S. 148A : Reassessment-Limitation-Effect of notification-Interpretation of taxing statutes-Notices issued pursuant to the case of UOI v. Ashish Agarwal (2022) 444 ITR 1/ 213 DTR 217/ 326 CTR 473/ 286 Taxman / AIR 2022 SC 2781 (SC)-Notice issued on or after 01.04.2021, the period concerned is between 01.04.2021 to 30.06.2021-Relaxation Act will not apply-The law as per Finance Act, 2021 has to be followed-Notice issued for Assessment years 2013-14 and 2014-15 are barred by limitation-The submission that the UOI v. Ashish Agarwal (Supra) would be applicable to the cases, where such notices have been challenged before different High Courts only, were not accepted. [S. 119, 147, 148, 148A(d), 149, 151, 151A, Taxation and Other Laws (Relaxation & Amendment of Certain Provisions) Act, 2020, S. 3(1), CBDT Instruction, 31-3-2021, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained expenditure-Bogus purchases-Violation of principle of natural justice-Information was not provided-Notice and order was set aside. [S. 148, 148A(b), 148(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained money-Violation of principle of natural justice-Flagged information on Insight Portal-Risk Management Strategy-Failure to furnish information-Notice and consequential proceedings pursuant thereto were set aside. [S. 143(1), 148, 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment-Notice in the name of non-existing company-Amalgamation-Notice issued in the non-existing company was quashed. [S. 147, Art. 226]

S. 148 : Reassessment-Notice in the name of dead person-Subsequent notice u/s 148A dated 6-6-2022 was not challenged-Writ petition challenging the earlier notice dated 3-5-20021 issued under section 148 was dismissed.[S. 148A, Art. 226]

S. 148 : Reassessment-Notice on dead person-Intimated in the original assessment proceedings-Notice and order was quashed. [S. 142(2) 159, 292BB, Art. 226]

S. 148 : Reassessment-Notice-Capital gains-Show cause notice-Disputed facts-Burden is on assessee-Since challenge to show-cause notice was based on disputed questions of facts, writ petition was dismissed. [S. 45, 147, Art. 226]

S. 147 : Reassessment-With in four years-Investment for purchase of property at Pali-Recorded reason the property mentioned at Delhi-reasons for reopening assessment were founded on non-existent transaction of purchase of property at Delhi, reassessment proceedings was quashed. [S.69, 148, Art. 226]

S. 147 : Reassessment-With in four years-Shares issued at premium to non-resident company-Valuation certificates were furnished under FEMA regulations-Income from other sources-Detailed explanation was furnished in the course of original assessment proceedings-No new material or information-Reassessment notice and order was quashed and set aside. [S. 56(2)(viib), 79, 148, R.11UA, Art. 226]