S. 147 : Reassessment-After the expiry of four years-Change of opinion-Disallowance of expenditure-Exempt income-Return was not filed in pursuance of notice u/s 148 of the Act-No hard and fast rule that the assessee should first file its return pursuant to the notice-Reassessment notice was quashed. [S. 14A, R. 8D, Art. 226]

S. 147: Reassessment-After the expiry of four years-Change of opinion-No failure to disclose material facts-Notice and order rejecting the objection was quashed [S. 33AC, 80A(2), 80I, 80M, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-No failure to disclose material facts-Mistake of Assessing Officer-Error discovered reconsideration of same facts does not give power to the Assessing Officer to reopen the assessment-Reassessment notice and order disposal of objection was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Audit query-Amount received towards corpus-Notice for reassessment and order disposing the objection was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Closing stock-Notional income-No failure to disclose material facts-Notice and order rejecting the objection was quashed. [S. 22, 23, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Survey-Borrowed satisfaction-Reasons cannot be improved or supplemented-No failure to disclose material facts-Assessing Officer cannot rely on various case laws while disposing the objection without furnishing the copies or brining to the notice of the assessee-Notice of reassessment and order disposing the objection was set aside. [S. 133A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Revenue audit-Insurance business-Income from dividend from equity shares and interest from tax savings bonds-Reassessment notice and order disposing objection was quashed. [S. 10, 44, 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Mandatory-Failure to follow the procedure under Section 144C(1) of the Act would be a jurisdictional error and not merely procedural error or a mere irregularity-Order of assessment was quashed and set aside. [S. 292B, Art. 226]

S. 144C : Reference to dispute resolution panel-Remand proceedings-Draft assessment order has not been issued before the final assessment order is passed-The order set aside. [S. 92CA, 254(1), Art. 226]

S. 144B : Faceless Assessment-Natural justice-less than two days to reply-Personal hearing was not given-Stricture-The Assessing Officer could not care for the assessee and was not even conscious of what he was actually doing-This is a pure form of harassment of the assessee, a tax payer-The entire approach smacks of high handedness and don’t care attitude-Directed the Assessing Officer to pay a sum of Rs 25, 000 as cost from his salary /personal bank account to PM Care fund-The matter shall be placed before different from the Officer who had passed the impugned order dated 22-4 2021-Order was set aside for denovo consideration. [Art. 226]