S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Alternative remedy-Writ is maintainable.[S. 148A(b), 148A(d),246A(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notices issued for asst. yr. 2015-16 are held to be invalid as same were issued during the extended period from 1st April, 2021 to 30th June, 2021 under TOLA. [S. 148,149(1),TOLA, S. 3(1), Art. 226]

S 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice under section 148 was issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Notice was quashed-Reopening notice had been issued after more than three years from end of relevant assessment year and thus, reopening without sanction/approval of specified authority in accordance with section 151 was bad in law-Assessee and CBDT entered into a unilateral Advance Pricing Agreement (APA) and assessee filed a modified return as per agreement, since no adverse report was received from TPO which could lead to cancellation of agreement, Assessing Officer had no jurisdiction to make further ALP adjustments and was bound to accept modified return.[S. 92CD, 147, 148, 148A(b), 148A(b) 151, 151A, Art. 226]

S 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Proceedings under sections 148A as also 148 ought to have been issued and proceeded in a faceless manner-Notice issued by jurisdictional Assessing Officer not in a faceless manner was bad in law and was t quashed and set aside. [S.68, 147, 148, 148A(b) 148A(d), 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Purchase of house in joint name-Cash credits-Entire consideration was paid by the husband-Reassessment notice in the name of wife was quashed and set aside.[S.68, 133(6), 148, 148A(b), 148A(d), Art. 226]

S. 148: Reassessment-Notice-Merger-Tribunal quashed the order-No specific direction for reassessment-Section 150 could not be invoked-Notice was time-barred and invalid under section 149.[S. 149, 150]

S. 144C : Reference to dispute resolution panel-Limitation-DRP’s proceedings was issued on 10-6-2022, uploaded in ITBA portal on 22-6-2022 and communicated to Assessing Officer on 4-7-2022, last date for passing impugned assessment order would have expired on 31-8-2022 and, thus, assessment order passed on 19-8-2022 was within period of limitation. [S.144C(13), Art. 226]

S. 144C : Reference to dispute resolution panel-Period of limitation-Date of uploading DRP order on ITBA Portal is to be considered as date of service to recipient and time for Assessing Officer to pass assessment order starts running from date of receipt of DRP order-Order was barred by limitation. [S.144C(13),153, 260A, 282]

S. 143(3): Assessment-Non-existent Oriental Bank of Commerce-Strictures-Prior intimation of merger and request for PAN cancellation-Since action had already been taken against Assessing Officer on administrative side, only token cost of Rs. 10,000 was imposed, payable to Gujarat State Legal Services Authority, instead of Rs. 1 crore proposed earlier for negligent assessment without independent verification and over-reliance on software systems. [Art. 226]

S. 139 : Return of income-Extension of due date—Date of filing audit report-Proposal for extension of return filing due date for auditable assessees for assessment year 2025-26 remained undecided and delay in e-filing utilities caused hardship, CBDT was directed to issue circular extending return filing due date to 30.11.2025 for assessment year 2025-26. [S.44AB, 119, Art. 226]