In the result, the outcome of the appeals and Cross Objections are as under:
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
reassessment proceeding covered by provision of section 147 to 151 where time for issuance of notice u/s 143(2) was left. Since the case of the assessee has already been considered as search case by Revenue in AY 2019-20 & AY 2020-21 while issuing notice u/s 148 directly without compliance of u/s 148A proceedings therefore