S. 148 : Reassessment-Notice-Liberty to assessee to file return under protest within one month without prejudice to his rights and contentions and seek reasons recorded-Order of High Court is affirmed with direction. [S. 147, Art. 226]

S. 147 : Reassessment-No objection raised to notice of reassessment in the assessment and appeal before CIT(A)-Participating in reassessment proceedings-Tribunal considering material on record and upholding reassessment proceedings-Order of Tribunal is up held. [S.143(1), 148, 260A]

S. 147 : Reassessment-Subsequent discovery by Income-Tax Investigation wing that transaction was bogus-The notice of reassessment is valid. [S. 148, Art. 226]

S. 147 : Reassessment-Order passed without considering objections to notice of reassessment-Order not valid. [S. 148, Art. 226]

S. 147 : Reassessment-Material leading to prima facie belief that income had escaped assessment-Reassessment notice is valid. [S. 148, Art. 226]

S. 147 : Reassessment-With in four years-Change of opinion-Specific query is raised in the course of assessment proceedings-It was not for the assessee to tell the Assessing Officer how he had to complete the assessment-Reassessment notice is not valid-Writ is maintainable. [S. 35D, 37(1), 148, Art. 226]

S. 147 : Reassessment-With in four years-Share capital-Share premium-Income from other sources-Produced evidence in support of increase of authorised share capital, share allotment and names and address of parties from whom share premium received-Change of opinion-Reassessment was quashed. [S. 56 (2)(viib), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Failure to disclose material facts-Audit party is entitle to point out a factual error-Subsequent discovery that facts regarding depositors was inadequate-Approval communicated to the Assessing Officer-b Notice valid. [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Expenditure prohibited by law-Amounts paid by Hospitals as referrals to Doctors-Not deductible-Interpretation of taxing statutes-Interpretation taking into account intention of legislature-Reassessment notice was quashed-Notice not valid. [S. 148, Art. 226]

S. 147 : Reassessment-With in four years-Share capital-Share premium-Income from other sources-Produced evidence in support of increase of authorised share capital, share allotment and names and address of parties from whom share premium received-Change of opinion-Reassessment order quashed by the High Court is affirmed. [S. 56 (2)(viib), 148, Art. 226]