S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sanction-Income escaped less than Rs. 50 lakhs-Notice issued after three years-Income from other sources-Notice is void ab-initio. [S. 56(2)(vii)(b), 148, 148A(b), 148A(d), 149, 151]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Initiated as per the decision of UOI v. Ashish Agarwal (2022) 286 Taxman 183/ 444 ITR 1 (SC)-Assessing Officer treated initial section 148 notice as section 148A(b) notice as per Supreme Court decision-Reassessment order was passed without issuing fresh section 148 notice-Order is without jurisdiction and void ab initio. [S. 147, 148, 148A(b), 148A(d)]

S. 147: Reassessment-After the expiry of four years-Cash credits-Cash deposited in to bank-AIR information-Non application of mind by the Assessing Officer-Reasons recorded by Assessing Officer for reopening assessment were based on factual errors, reopening notice was void ab initio. Reassessment order is quashed. [S. 68, 143(3), 148]

S. 145 : Method of accounting-Whole sale food items-Estimation of net profit-Matter is remanded back to Assessing Officer to adjudicate afresh.

S. 143(1) : Assessment-Intimation-Prima facie adjustment-Excise duty-Adjustment made by Assessing Officer under section 143(1) by including excise duty in turnover is not sustainable.[S.143(1)(a), 145A]

S. 115-O : Domestic companies-Tax on distributed profits-Income-Deemed to accrue or arise in India-Dividend-DTAA does not get triggered when a domestic company pays DDT under section 115-O-Order of the AO rejecting the claim of refund of excess DDT is affirmed.-DTAA-India-Italy [S.9(1)(iv), Art. 11]

S. 115BAC : Tax on income of individuals and Hindu Undivided Family-Old scheme-New tax scheme and filed form 10-IE while filing revised return, requirement of filing Form 10-IE was directory in nature and not mandatory and it was sufficient compliance if said form was before Assessing Officer at time of assessment.[S.139(1), 143(1) R. 21AG(1), Form No 10-IE]

S. 80G : Donation-Rejection of application-Pendency of fresh application-Appeal is dismissed as infructuous. [S.80G(5)(viii), Form No 10AB]

S. 90 :Double taxation relief-Investment fund-Capital gains-Shares, units, transfer of-Conduit entity without any economic substance-Not justified in denying benefits under article 13 on long term capital gains-DTAA-India-Mauritius [S.9(1)(i)), 90(2) Art. 13(4)]

S. 80IC : Special category States-Partnership firm to company-Change in status of company in terms of its composition does not brings into action provisions of section 80IC(4)(ii)-Entitle to deduction. [S 80IC(2)(a)(ii), 80IC(4)(ii)]