S. 147 : Reassessment-After the expiry of four years-Shares or Derivatives-Reopening of Assessment has to be Tested or examined only on basis of reasons recorded and cannot be supplemented by affidavits-Notice vitiated by non-application of mind. [S. 148, 151, Art. 226]

S. 144C : Reference to dispute resolution panel-Faceless Assessment-Limitation period for completion of Assessment by Assessing Officer on receipt of order of Dispute Resolution Panel against draft Assessment order-Not falling within period from March 20, 2020 to December 31, 2020 as stipulated under Section 3(1) of Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020-Assessment order barred by time and consequent demand and penalty notices set aside. [S. 143(3), 144B, 144C(1), 144C(5), 144C(13), 156, 270A, 274, Art. 226]

S. 144C : Reference to dispute resolution panel-Limitation-Limitation prescribed by Section 153 Applies-Direction issued to Deputy Commissioner to take up the entire matter of the assessee for consideration at the earliest and take an appropriate decision in accordance with law, within a period of four weeks from the date of receipt of this order and pass an appropriate order in writing. [S. 153, Art. 226]

S. 144B : Faceless Assessment-Violation of principle of natural justice-Extension of time to submit reply to notice was rejected Assessment order set aside. [S. 144B(1)(xvi), Art. 226]

S. 144B : Faceless Assessment-Draft Assessment order-Variation in income-Assessee must be given opportunity to be heard. [S. 144B(1)(vi)(b), Art. 226]

S. 143(3) : Assessment-Principles of natural justice-The right of a man to have a fair opportunity of hearing is fundamental to any civilised legal system-Effective opportunity to be heard not given-Order of assessment set aside. [Art. 226]

S. 143(3) : Assessment-Ex parte order-Failure to attend due to ill health-Order set aside. [S. 142(1), Art. 226]

S. 143(3) : Assessment-Amalgamation of companies-Corporate death of entity upon amalgamation cannot invalidates Assessment order-No intimation regarding amalgamation nor revised return filed though time available after amalgamation-Notice issued-Conduct of assessee from date of search and before all forums consistently holding itself out as assessee-Assessment valid-Matter restored to Tribunal to hear appeal and cross-objections on merits. [S. 2(1A), 142(2A), 143(2), 153A, 170; Companies Act, 1956, S.394, 481]

S. 142(2A) : Inquiry before assessment-Special audit-Voluminous material seized during Search-Bogus claims-If two or three queries out of forty five queries unwarranted, entire order giving directions could not be treated as nullity-Directions neither arbitrary, illegal nor beyond scope of provision. [Rule 14A, Form 6B]

S. 132A : Powers-Requisition of books of account-Cash undisclosed seized by Excise Authorities-Deposited with Judicial Magistrate-Order giving only part of cash to Income-Tax Authorities-Not valid. [S. 131, Code of Criminal Procedure, 1973, S. 451]