S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Faceless Assessment – Personal hearing through video conference – Opportunity of hearing denied – Matter remand – [ S. 144B , 147 , 148, Art , 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice -No reasoning or any discussion found on the contention raised – Order set a side for passing a speaking order. [ S. 148A(d), Art , 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Order passed on the different ground – Contrary to CBDT Circular dated Ist August 2022- Order was quashed. [ S. 148A(b) ,148(a)(d), 151, Art , 226 ]

S. 147: Reassessment -Order – Capital gains – Computation – Alternative remedy – Writ petition was dismissed [ S. 45 ,143(3), 148, 220(6) , Art , 226 ]

S. 147 : Reassessment – With in four years- Wrong facts – Re-opening based on wrong facts is impermissible- Typographical error/ oversight in the reasons recorded for re-opening is not sustainable to uphold the re-assessment proceedings. [ S. 148 , 151, Art , 226 ]

S.147: Reassessment – After the expiry of four years – Capital gains – Penny stock – No failure to disclose material facts – Reassessment notice was quashed [ S. 45, 148 , Art 226 ]

. 144B : Faceless Assessment – Opportunity of hearing – Physical hearing not mandatory Assessee did not opt for virtual hearing even after being advised to do so – Assessment order cannot be challenged [ S. 144B(7), Art , 226 ]

S. 144B : Faceless Assessment – Vested right to a personal hearing – Order was set aside and the matter was to be remanded back to Assessing Officer for a fresh decision. [. 143 (3), 144B(7) (vii), Art , 226 ]

S. 92C : Transfer pricing – Arm’s length price – It is necessary that the controlled transactions be compared with uncontrolled transactions which are similar in all material aspects which determining the ALP. Since the comparable company fails in not only the service revenue from export/ ITES filter of 75% taken by the TPO but also the diminishing revenue filter and thus the Tribunal was correct in excluding such comparable.[ S. 133(6) ]

S. 80IA: Industrial undertakings – Interest – Generation of power – Interest income earned from advance given to employees during the course of business and also interest income earned from bonds issued by the sole customer to whom electricity is supplied is eligible for deduction. [ S. 80IA(4)(iv)]