S. 153D : Assessment-Search-Approval-Sanction must be accorded only after due consideration. [S.260A, 292B]

S. 153D : Assessment-Search-Approval-Approval is granted without application of mind-Assessment order is quashed-SLP dismissed. [S.292B, Art. 136]

S. 153C : Assessment-Income of any other person-Search-Opportunity of hearing was granted-Order is valid-Writ petition is dismissed.[Art. 226]

S. 153C : Assessment-Income of any other person-Search-Issue raised in a writ petition was dismissed-Subsequent writ petition on same issue but with different grievance-Writ petition is dismissed as not maintainable.[Art. 226]

S. 151A : Faceless assessment of income escaping assessment- Reassessment-Notice-Jurisdiction-Scheme-Procedure adopted by Department in contravention of statutorily prescribed procedure-Office Memorandum cannot override mandatory specifications in scheme-Reassessment notice is set aside-Department given liberty to proceed in accordance with amended provisions. [S. 144B, 147, 148, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Amendment of Section 151 with effect from 1-4-2021-Issue of notice in respect Of Assessment years 2016-17 and 2017-18 notice is not valid-Interpretation of taxing statutes-Proviso. [S. 147, 148,149(1), 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Bar Of Limitation-Initiation of proceedings from 1-4-2021-Notice issued beyond period of limitation of six years-Notice and order is quashed and set aside. [147, 148, 148A(d), 149, Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sanction for notice issued by Income-Tax Authority which did not have jurisdiction-Notice is not Valid.[S. 147, 148, 151, Art.226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Time granted to respond to notice lesser than prescribed seven days-Opportunity of personal hearing not granted-Notices and order set aside. [S. 147, 148, 148A(b). 148A(d),151A Art. 226]

S. 147 : Reassessment-Non-Resident-Permanent Establishment-Transactions found to be at arm’s length-Supplying materials through direct imports to Indian Railways-Allegation of wholly owned subsidiary-No material to prove conclusively that Indian Subsidiary’s place assessee’s Permanent Establishment falling in any of three Categories. Petition is allowed. Liberty is given to Department to independently examine whether Delhi Office of assessee a Permanent Establishment or service Permanent Establishment-DTAA-India-USA. [S.92CA, 133A, 148, Art.5(1), 5(2), 5(3), 5(4)]