S. 148 : Reassessment-Notice-Proceedings for rectification of mistake dropped after considering reply-Reassessment proceedings cannot be held to be invalid. [S. 147, 154]

S. 148 : Reassessment-Notice-Minor-Form No 26AS-No reasons were recorded by the Assessing Officer Ward 6(3), who has issued the notice-Notice was not issued by the Jurisdictional officer-Objection was not raised in the course of assessment proceedings-After participating in the assessment proceedings and completion of assessment the jurisdictional issue cannot be raised-Non application of mind by the sanctioning Authority-Reassessment was quashed. [S. 4, 5, 64(IA), 124(3), 133(6), 147, 151, Contract Act, 1872, S. 11]

S. 148 : Reassessment-Notice-Time limit for issuance of notice u/s 143(2) has not expired-Reassessment notice is bad in law [S. 143(2), 147]

S. 148: Reassessment-Notice-Non filing of ITR-Agriculturist-Deposits of cash in assessee’s bank-Deposit in nature of exchange of agricultural land-Order passed by Assessing Officer without reason to believe and proper verification-Recorded statements not supplied to assessee-Additions made on suspicion-Additions deleted-Reassessment quashed. [S. 147]

S. 148: Reassessment-Notice-Reason to be formed before Issue of notice-Reassessment not valid. [S. 50C, 147]

S. 147 : Reassessment-Bogus purchase-Reopening based on investigation of CBI held valid-Non-filer and did not provide for details to substantiate the transactions-. Addition to the extent of 12.50% was held to be justifiable. [S. 68, 69C, 148, 143(3)]

S. 147 : Reassessment-Penny stock-Report of investigation wing-Reasons recorded were generic and based on borrowed satisfaction of investigation wing-No live nexus between tangible material and reason recorded-Reopening was based on mere suspicion-Reassessment is bad in law [S. 10(38), 45, 68, 148]

S. 147 : Reassessment-Communication of reason to believe-No violation of directions of Supreme Court in GKN Driveshaft (India.) Ltd.’s case-Reassessment is valid [S. 148]

S. 147 : Reassessment-Tangible material-Reasons Communicated to Assessee bearing signature of Assessing Officer and approved by CIT(E)-Sanction of Commissioner-Reassessment notice is valid-Jurisdiction-Merely because assessee had surrendered registration jurisdiction of Assessing Officer of exemption circle would not automatically change-Jurisdiction not choice of assessee-Reassessment notice issued by Officer of Exemption circle valid-Registration under section 12AA had been cancelled with retrospective effect, the challenge to the denial of exemption under section 11 was untenable-Levy of interest under section 234B of the Act was consequential and accordingly, to be dismissed [S. 11, 12, 12A, 12AA, 120, 148, 151, 234B]

S. 147 : Reassessment-Jurisdiction-Notice issued by Assessing Officer not having jurisdiction-Order passed by jurisdictional officer-Reassessment is void ab initio. [S. 120, 124, 127, 148]