Best judgement assessment empowers assessing officer to determine tax base on noncooperation, subject to hearing safeguards.

Clause 163 empowers the Assessing Officer to make a best judgement assessment of the tax base when the assessee fails to comply with statutory notices, directions or return obligations, departs from prescribed accounting methods or where accounts are not reliable. The officer must consider all relevant material on record and, as a rule, serve a show-cause notice providing an opportunity of being heard before completing the assessment, although that hearing may be omitted where a notice under section 157 has been issued.

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