S. 149: Reassessment-Time limit for notice-Notice dated 31.08.2024 issued under section 148 is beyond the period of six years from the end of Assessment Year 2016-17; therefore, the same is time-barred; SLP dismissed on account of delay of 309 days and also on merits. [S. 148, Art, 136]

S. 149: Reassessment-Time limit for notice-The statutory six-year period for reopening expired on 31-03-2021; a notice issued under section 148 on 30-08-2024 was barred by limitation and therefore without jurisdiction; SLP of the revenue dismissed on account of delay of 327 days and also on merits. [S. 147, 148A, Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Audit objection-Review/change of opinion on the same material, which is impermissible-Notice and consequential orders were set aside-Notice issued under section 148 on 31-3-2023 was beyond four-year limitation under first proviso to section 149 as applicable, so extended six-year period did not apply, rendering such notice and subsequent proceedings invalid and liable to be quashed. [S. 147, 148, 148A(b), 148A(d),149, Art . 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Investigation Wing-Unexplained moneys-Reassessment is valid where reopening is based on fresh tangible material received subsequently, and therefore does not amount to a change of opinion, even if the issue was examined in the original scrutiny assessment. [S.69A, 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Information from Investigation Wing-At the section 148A stage, furnishing information suggesting escapement of income is sufficient; non-supply of the complete underlying material does not vitiate the notice. [S. 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order under section 148A (3) was passed on a ground not forming part of notice issued under section 148A (1)-Notice issued under section 148 pursuant to such order passed under section 148A (3) of the Act is bad in law. [S. 148, 148A(b), 148A(d),148A(3), Art . 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Dividend received from mutual funds-Reopening of assessment cannot be sustained when it is based solely on third-party survey findings, without any tangible material linking the assessee to the alleged sham transactions. [S. 10(35), 133A, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Purchase and sales-The assessee had dealt with information supplied to it by the revenue and had meticulously satisfied the data by comparing it with books of account-Reassessment notice and consequential orders were quashed. [S. 68, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Claim of depreciation disallowed in earlier year has been deleted in appeal proceedings by Appellate Tribunal-Reopening notice issued for subsequent assessment year to disallow the claim of depreciation in contravention of the order passed by Appellate Tribunal is against the settled provisions of law-Reassessment notice and consequential orders were quashed by High Court-SLP of revenue was dismissed on account of delay of 124 days as well as on merits. [S. 32, 32AC, 92BA,148 Art . 136]

S. 148: Reassessment-Notice-Limitation-Notice under section 148 issued on 23-4-2022 for assessment year 2015-16, being issued after 1-4-2021, was beyond limitation and without jurisdiction-Notice and consequential orders were quashed and set aside. [S. 144, 144B, 147, Art . 226]