S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Sanction-Specified Authority-Sanction from Principal Commissioner-Not from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General and not under section 151(i)-Prior approval was taken from Principal Commissioner in terms of section 151(i) and not by specified authority under section 151(ii)-Order as well as notice issued under section 148 is bad in law hence quashed and set aside. [S. 148, 148A(b) 148A(d), 151 (i) 151 (ii), Art. 226]

S. 149 : Reassessment-Time limit for notice-Assessing Officer had proceeded without jurisdiction by applying amended provisions of section 149 to case in hand when he issued notice on 25-7-2022 overlooking fact that limitation had already expired on 31-3-2020-Reopening notice issued under section 148 is quashed.[S. 148, 149(1)(b) Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained money-Sale consideration received in cash-Sale by Power of Attorney holder-Since a detailed adjudication on merits of information available with Assessing Officer and defence set up by assessee is not contemplated at stage of passing an order under section 148A(d)-Writ petition is dismissed.[S. 69A, 148, 148A(b), 148A(d), Power of Attorney Act, 1882, Art. 226,]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amounts of investments not fully disclosed in books of account-Report from District Valuation Officer (DVO)-Fixed asset and Capital WIP-Failure to apply mind-Reassessment notice and order disposing the objection is quashed.[S. 48, 69A, 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Violation of principle of natural justice-Order passed without considering the documents submitted by the assessee-Assessment order is set aside and matter is remanded for reconsideration from stage of reply to show cause notice cum draft assessment order.[S. 69, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Immovable property-Added entire sale consideration-[S. 69, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Officer who has issued the notice and heard the matter-Order is passed by the Officer who has not heard the matter-Order and notice is set aside.[S. 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Project competition method-Method of accounting-Tax deducted at source-Mandatory to pass speaking order-Reassessment notice is bad in law-Faceless assessment-JAO had no jurisdiction to issue notice under section 148 as per requirements of section 151A read with section 144B.[S. 143(1),144B, 145, 148, 148A(b), 148A(d), 151, 151A, 194IA, Art. 226]

S. 147 : Reassessment – After the expiry of four years – Unexplained moneys – No return is filed within time allowed – Not explained receipt of amount – Reassessment notice is held to be valid – Writ petition is dismissed. [ S.69A, 148 , Art. 226 ]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sale of immovable property-Failure to reply-Reasonable cause-In view of submissions made by assessee, assessment order and penalty order is set aside on condition that assessee would remit a sum towards income tax demand, as agreed to, and submit a reply to show cause notice-Matter remanded- Petitioner is directed to deposit Rs .2,00,000 lakhs towards income -tax demand . [S. 143(3), 148, 148A(b) 148A(d),Art. 226]