Assessment reopening under section 147: assessee can seek dropping proceedings if original assessment equals correct liability; transitional rules preserved. Section 152 provides that tax on assessment, reassessment or recomputation after reopening is charged at the rate(s) as if the income had not escaped; an ... Summary
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Assessment reopening under section 147: assessee can seek dropping proceedings if original assessment equals correct liability; transitional rules preserved.
Section 152 provides that tax on assessment, reassessment or recomputation after reopening is charged at the rate(s) as if the income had not escaped; an assessee who has not impugned the original assessment may seek dropping proceedings by showing the original assessment equals or exceeds the correct liability, subject to bar on reopening matters concluded by specified review or rectification orders; transitional rules preserve pre-amendment reopening and reassessment procedures for cases from certain searches, requisitions, surveys or notices issued within the transition window.
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