S. 153A: Assessment-Search-Unaccounted income –Capital gains-Statement retracted-Retracted statement could not be termed as incriminating material-No addition could be made in respect of completed assessments on the basis of such retracted statement. [S. 132 (4), 132A, 260A]

S. 153A : Assessment-Search or requisition-Warrant of Authorisation-Panchnama-No search against the assessee-Panchanama reflected the name of the assessee-Panchnama cannot be treated as warrant of authorisation-Assessment order is quashed as without jurisdiction-Existence of alternative remedy-Not bar to entertainment of writ petition where challenge is to jurisdiction exercised by Authority and interpretation of statutory provisions involved-SLP of revenue dismissed. [S. 132,153D, Art.136]

S. 151A: Faceless assessment scheme-Jurisdiction to issue notice of reassessment lies with the faceless Assessment Officer, not the jurisdictional Assessing Officer-Notice and consequential order invalid.[S. 147, 148, 148A(b) 148A(d), Art.226]

S. 151A: Faceless assessment scheme-Faceless Assessment-Reassessment-Jurisdiction-Mandatory-Notices and orders issued by jurisdictional Assessing Officer-Invalid and to be quashed-Liberty to Department to revive petitions if Supreme Court holds in its favour. [S. 148 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accumulation of income-The Assessing Officer had looked into the relevant details and particulars of accumulation during the course of the original assessment, and the assessee had provided all the details and documents during the original assessment proceedings-The order initiating the reassessment was based not only on a change of mind but also on non-application of the mind-Show cause notice and order quashed. [S. 11(2), 148, 148A(b) 148A(d), R. 17, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Strictures-Assessing Officer before issuance of notice to verify information made available on Insight Portal which suggests that income chargeable to tax has escaped assessment-If necessary, Assessing Officer must conduct inquiry with prior approval of specified authority with respect to such information and only thereafter invoke provisions-Court observed that in future, no such action would be taken by authorities on basis of information made available on Insight Portal without verification by jurisdictional Assessing Officer.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice after six years Limitation-Order passed under section 148A(d) and consequent notice dated 1-5-2024 issued under section 148 after expiry of limitation period of six years on 31-3-2024-Barred by limitation-Faceless assessment-Faceless Assessment Officer has exclusive jurisdiction to issue notice-Notices issued and order passed by Jurisdictional Assessing Officer in contravention of provision invalid-Notice and order set aside.[S. 80-IA, 147, 148, 148A(b),148A(d), Art.226]

S.147: Reassessment-After the expiry of four years-No new material-Change of opinion-Lease back-Notice and consequential proceedings quashed and set aside.[S. 143(1), 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Non eligible assessee-Assessing Officer cannot pass draft assessment order under section 144C(1)-Draft assessment order, final assessment order and notices of demand and penalty set aside. [S. 92CA(3), 143(3), 144C(15), 156, 270A, 271AAC, Art. 226]

S. 143(3): Assessment-Assessment order passed in disregard of principles of natural justice and to be quashed-Strictures-Direction to CBDT –False affidavit by the Revenue before High Court-Assessment order quashed-CBDT is directed to take appropriate action. [S.11, 12, 12A(b) R. 17B, Form No. 10B Art. 226]