S. 148A : Reassessment – Conducting inquiry, providing opportunity before issue of notice – Alternative remedy -Writ petition against show cause notice is not maintainable – Writ petition was dismissed. S. 147, 148 148A(d), 246A, Art, 226]

S. 148A : Reassessment – Conducting inquiry, providing opportunity before issue of notice – Natural justice – Opportunity of hearing requested but not afforded -Opportunity of cross examination was to be granted – Order and notice was set aside -Matter remanded to Assessing Officer. [S. 147, 148, 148A(d), Art. 226]

S. 147 : Reassessment – After the expiry of four years-Information received from Investigation Wing-Assessee’s own statement during survey- Search of third party -Disputed question of fact- Alternative remedy -Writ petition was dismissed. [S. 132, 133A, 143(1), 148, 151(1), Art. 226]

S. 147 : Reassessment -Notice after six years-Sanction-Notice dated 30-3-2021 issued under old provision after coming into effect of new provision from 1-4-2021 -UOI v. v. Ashish Agarwal(2022) 444 ITR 1 (SC) – Notice and subsequent orders and proceedings are quashed. [S. 148, 151, Art,226]

S. 147 : Reassessment -Residential Status -Resident or non-resident -Service of notice on chartered Accountant – Reassessment notice was held to be valid- Interest- Levy of interest -Automatic -Working in ITNS 150 forming part of assessment order was proper -Sikkim -Commission -Burden not discharged -Round tripping of funds -Liable to tax in India. [S. 2(35), 5, 6(3)(ii), 131, 142(1), 143(2), 148, 234A, 282]

S. 147 : Reassessment –With in four years-Speculative transactions-loss of cancellation of forward contract-Change of opinion-No new material -SLP of Revenue dismissed. [S. 43(5), 148, Art. 136, 226]

S. 147 : Reassessment-After the expiry of four years-Book profit-Revision was dropped-Sanction for reassessment was without application of mind-Reassessment notice and order disposing the objection was quashed.- SLP of Revenue was dismissed. [S. 148, 151, 263, Art. 136, 226]

S. 147 : Reassessment -After the expiry of four years -No failure to disclose material facts -Change of opinion – Reassessment notice and order disposing the objection was quashed by the High Court was affirmed. [S. 143(3), 148, Art. 136, 226]

S. 147 : Reassessment-Notice after six years-Notice issued prior to 1-4-2021 more than six years after expiry of Assessment year – High Court quashed notice and orders- SLP of Revenue is dismissed. [S. 148, Art. 136, 226]