S. 149: Reassessment – Foreign asset – HSBC Geneva account of Trust – Time limit for notice – 16 years – Assets held outside India – Introduced vide Finance Act, 2012 – Retrospective in nature. [S. 147, 148, 151]

S. 147 : Reassessment-After the expiry of four years-Shipping business-Reserves-Dividend and long term capital gains-No failure to disclose material facts-Return was not filed in pursuance of notice issued u/s. 148 of the Act-There is no hard and fast rule that the assessee should file the return pursuant to notice, when the reasons do not disclose on the face of it any failure on the part of the assessee to disclose all material facts necessary for assessment-Reassessment notice was quashed. [S. 33AC, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Interest expenses-No failure to disclose material facts-Reassessment notice was quashed. [S. 57, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Seeking clarification-Retention money-No failure to disclose material facts-Reassessment is bad in law. [S. 148, Art, 226]

S. 147 : Reassessment-After the expiry of four years-Directed to pass speaking order while disposing the objections after considering the objections of the assessee-Assessment order was quashed and set aside. [S. 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Power of enhancement-Any matter relating to assessment-Writ was dismissed. [S.92C, 144C(8), Art, 226]

S. 144B : Faceless Assessment-Cash credits-Violation of principle of natural justice-Two days’ time was not granted-Draft assessment order was not provided-Assessment order was set aside. [Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-Opportunity of personal hearing was not granted-Order was set aside-Directed the Assessing Officer to pass a reasonable order in accordance with law. [S. 143(3), 144B(7), Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-Without affording personal hearing-COVID-19-Order was set aside and remanded back for adjudication a fresh. [S. 143(3), Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-No show cause notice and draft assessment order was issued-Assessment order was set aside and remanded back to Assessing Officer. [Art. 226]