S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Bogus purchases-Accommodation entry providers-Assessing Officer not required to conclusively determine escaped income at threshold stage Order and notice for reopening assessment upheld-Issue regarding jurisdiction of Assessing Officer to initiate reassessment proceedings in faceless assessment regime is no more res integra-Writ petition was dismissed-SLP of assessee dismissed. [S. 147, 148, 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-High Court holding writ will not lie and grievances on merits to be agitated by assessees in reassessment proceedings before Assessing Officer-Supreme Court Concession of Department before Supreme Court in UOI v. Rajeev Bansal (2024) 469 ITR 46(SC) that all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020-Notices dated 25-6-2021 quashed.[S. 147, 148, 148A(b), (d) Art, 226.]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Pendency of appeal-SLP of assessee dismissed.[S. 148A(b), 148A(d), Art. 136]

S. 148 : Reassessment-Notice-Limitation-Last date for issue of notice expiring on 31-3-2021-High Court holding notices dated 31-3-2021 had left Income-tax Business Application portal on or after 1-4-2021-Order was barred by limitation-SLP of revenue was dismissed. [S. 147,149, Art. 136]

S. 147: Reassessment-Change of opinion-Search-No tangible material-Discovery of cash-Reassessment notice and order disposing the objection was quashed.[S. 132, 147, 148, 153A, Art. 226]

S. 147 : Reassessment-Capital gains-Borrowed satisfaction-Notice and order rejecting assessee’s objections set aside.[S. 10(38),45, 148, Art. 226]

S. 147: Reassessment-Jurisdiction-Power to call information-Commission receipt-Incorrect assumption-Non-application of mind by Assessing Officer-Electronic system failure to record reply would not justify initiation of reassessment-Notices quashed and reassessment proceedings vitiated.[S. 133(6), 148 Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose all material facts-Borrowed satisfaction-Notice and order disposing the objection was quashed. [S. 143(3), 148, Art. 226]

S.147: Reassessment-After the expiry of four years-Bad debt-Write-off of bad debt-Not required to be proven-Writ appeal allowed-Reassessment notice and order disposing the objection was quashed. [S. 36(1)(vii), 148,Art. 226]

S. 147 : Reassessment-Exchange, difference or net loss in foreign exchange transaction-Change of opinion-No tangible material-SLP of revenue dismissed, the delay of 181 was not satisfactorily explained and also on merits. [S. 143(3), 148, Form 15CA, Art. 136]