S. 149 : Reassessment-Time limit for notice-Provisions of relevant assessment year applicable for reassessment proceedings. [S. 147 148,149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Incorrect premise-Reassessment notice based on incorrect assumption of non-filing of return-Held to be invalid-Order cannot be justified on basis of reasons supplied subsequently-DTAA-India-Mauritius [S. 9, 147,148, 148A(b), 148A(d), Art. 13(4), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-No opportunity of being heard-Violation of principles of natural justice-Reassessment notice u/s 148 and order u/s 148A(d) quashed [S. 148A(b), 148A(d), 149(1)(a), 149(1)(b)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-The interest income received from Non-Convertible Debentures (NCDs) was appropriately taxed under section 194LD, and could not be characterized as dividend liable for Dividend Distribution Tax (DDT) under section 115-O-Nexus between material relied on and formation of belief is necessary-Recorded reasons cannot be substituted-Notice and order disposing the objection is quashed. [S.115O, 147, 148, 148A(b), 148A(d), 194LD, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order is passed without giving assessee adequate opportunity to reply to the initial notice-Order is not valid-Matter is remanded back to the Assessing Officer. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Petitioner had explicitly sought for a personal hearing-Not granted-Breach of the principles of natural justice-Order is set aside.[S. 148A(b), 148A(d), Art. 226]

S. 148 : Reassessment-Notice-Merger-Non Existing entity-Notice issued to a non-existing entity post-merger was a substantive illegality and not some procedural violation-Notice and order is quashed and set aside. [S.147v 292B, Art. 226

S. 148 : Re-assessment-Notice-Notice issued in the name of amalgamating company instead of amalgamated company-Not a curable defect-Notice is invalid. [S.260A, 292B].

S. 148 : Reassessment-Notice-Amalgamation-Failure to intimate the amalgamation-Petition is dismissed. [S. 147, Art. 226]

S. 148 : Reassessment-Notice-Amalgamation-Informed the factum of amalgamation-Reassessment in the name of non-existent amalgamating entity a nullity-Not curable defect cannot be validated under section 292B-Notice and consequential order is quashed. [S. 147, 292B, Art. 226]