S. 148 : Reassessment-Issue of notice-Unsigned notice-Notice neither manually nor digitally signed-Statutory mandate of section 282A violated-Defect not curable under section 292B or section 292BB-Notice and all consequential proceedings quashed. [S. 147, 156, 271(1)(c), 282A, 292B, 292BB, Art. 226]

S. 148: Reassessment-Notice-Jurisdiction-Reassessment proceedings initiated under section 148 without complying with the mandatory faceless assessment procedure under section 144B are invalid in law, and the notice as well as all consequential proceedings are liable to be quashed. SLP of revenue dismissed. [S. 144B, 147, Art. 136]

S.147: Reassessment-Income from house property-Interest-Lender’s certificate-Property was let out throughout the year-Audit objection-Annual value was determined under section 23(1)(b), restriction under proviso to section 24(b) did not apply-Absence of any fresh tangible material-Reassessment notice and order disposing the objection were quashed and set aside. [S. 22, 23(1)(b), 24(b), 148, Art . 226]

S. 147: Reassessment-Within four years-Deemed dividend-Interest-free loan from company-Earlier reassessment and proposed addition as deemed dividend under section 2(22)(e) was dropped-Subsequent reopening by invoking section 2(24)(iv) on the same loan amounted to mere change of opinion and was impermissible-Reassessment notice and order disposing of the objection were quashed. – Strictures – Subjecting the petitioner to reassessment proceedings a second time for the self-same transaction and practically for the same issue is arbitrary and without jurisdiction. They fall foul of the petitioner’s fundamental and constitutional rights guaranteed under Article 14, Article 19(1)(g) and Article 300A of the Constitution of India. A Cost of Rs .1,00,000 was imposed upon the respondent for each of the assessee.[S. 2(22)(e), 2(24(iv), 148, Art. 14, 19(1)(g) , 300A , 226]

S. 147: Reassessment-Notice for reassessment to examine the issue of depreciation already examined by the AO during the course of original assessment is untenable and liable to be quashed-SLP dismissed on account of delay of 426 days as well as on merits. [S. 32, Art . 136]

S. 147: Reassessment-Notice issued on the ground that dividend income does not qualify for exemption under section 10 (34) of the Act-issue of exemption claimed by the assessee was duly examined during the original assessment proceedings-notice is based on change of opinion and the same is void ab initio-SLP dismissed on account of delay of 124 days as well as on merits. [S.10(34), 115-O, Art . 136]

S. 147: Reassessment-Reassessment notices issued merely on the basis of third-party search information, without any material linking the assessee to the alleged escaped income and with reasons recorded mechanically without independent application of mind, are invalid and quashed; SLP dismissed. [S. 69, 132, 148 Art. 136]

S. 147 : Reassessment-Within four years-Audit objection-CSR expenditure-Notice and order disposing of the objection were quashed by the High Court-SLP of the revenue dismissed. [S. 37(1) 148, Art, 136]

S. 147: Reassessment-Lease rent-Unrealised gain-Depreciation-Absence of fresh tangible material-Reopening cannot be initiated on repetitive lease rent transactions accepted in past scrutiny assessments, unearned/unrealized foreign exchange hedging variations, or by applying prospective amendments on goodwill depreciation retroactively-SLP of revenue dismissed. [S. 32(1), 37(1),43(6) (c), 148, Art. 136]

S. 145: Method of accounting-Income-Accrual-Real income theory-Interest accrued on NPA loans is taxable where the assessee’s own conduct, such as extending further credit to the same borrowers, shows a realistic prospect of recovery; RBI Prudential Norms do not govern taxability under the Income-tax Act. [S. 4, 5]