Sec. 92CA, 147 & 148 of Income-tax Act, 1961 — Reassessment - The petitioner challenged the impugned notices issued to him under s. 148 r/w s. 147 of the IT Act, 1961 as well as the under s. 92CA of the Act. High Court disposed off the Writ petition holding that ”the reasons recorded for reopening of the assessment under s. 147 of the Act do not indicate any escapement of income due to the wrong TP adjustment/ALP. On the other hand, it is confined to the disallowance under s. 14A of the Act. The action of the respondent No. 1 in referring the matter to the respondent No. 2 for TP adjustment cannot be countenanced at this stage. Hence, the impugned notices issued under s. 92CA of the Act are quashed. The respondent No. 1 shall consider the objections submitted by the petitioner and dispose of the same in accordance with law in an expedite manner“. - ESSILOR INDIA (P) LTD. V/s ASSTT. CIT - [2020] 315 CTR 199 (KARN)