S. 148 : Reassessment-Writ-Maintainability-Notice u/s 148 is only a show-cause notice-No interference under Art. 226-Assessee free to raise objections before AO . [S.147, Art.226]

S. 147 : Reassessment-Principle of natural justice-Order passed in hurry to avoid time getting barred and without giving assessee adequate opportunity to be heard-Not valid.[S.143(1), 148, 153, Art. 226]

S. 147: Reassessment-Notice-Crime Investigation Bureau-Mere receipt of information regarding such escapement Notice based on information not valid.[S. 148,151, Art. 226]

S. 147: Reassessment-Notice-Change of opinion-Report of the Directorate General of Goods and Services Tax Intelligence was considered in the original assessment proceedings-Reopening of assessment on the basis of same report is change of opinion-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]

S. 147: Reassessment-Foreign assets-Notice issued pursuant to liberty granted by Supreme Court relating to foreign assets-Supreme Court decision in first round of litigation binding on parties Sufficient material existed to justify reassessment.[S. 68, 92B, 147, proviso (ii), 148, Art. 142, 226]

S. 147 :Reassessment-Faceless Assessment-Natural justice-Matter remanded to Assessing Officer to proceed in accordance with law.[S. 144C, 147, Art. 226]

S. 147 : Reassessment-Notice-Failure to respond notices-Natural justice is not violated-Division bench held that the Single judge right in relegating assessee to remedy of statutory appeal Extension of time granted to file appeal before appellate authority-Stay of coercive proceedings until outcome of order in statutory appeal.[S. 148, 246A, Art. 226]

S.147: Reassessment-After expiry of four years-No failure to disclose material facts-Change of opinion-Dividend from trust-Investment allowance wrongly claimed-Reopening invalid. [S. 2(22)(e), 10(34), 32AC, 143(3), 148, Art. 226]

S. 147: Reassessment-Foreign assets-Notice issued pursuant to liberty granted by Supreme Court relating to foreign assets-Supreme Court decision in first round of litigation binding on parties Sufficient material existed to justify reassessment-SLP dismissed-Corporate guarantee the issue is kept open. [S. 68, 92B, 147, proviso (ii), 148, Art.136, 142]

S. 144C : Reference to dispute resolution panel-Objections raised by assessee must be considered before order is issued-Order passed without waiting for directions of Dispute Resolution Panel on assessee’s objections Liable to be quashed Assessing Officer to await directions of Dispute Resolution Panel. [S. 144C(5) 144C(6) 144C(10) Art.226]