TaxTMI 
TaxTMI 
Hi,
Can a SCN be issued based on new issues after objections in ADT 02 has been accepted and paid? Are there any case laws to support that no such SCN can be issued?
SCN after ADT 02
05 Nov 2024 
9 Replies 
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Show-cause notices after audit conclusion: fresh evidence can prompt SCNs, subject to limitation and concealment rules.
The audit conclusion under ADT-02 functions as an intimation of findings at the end of the audit visit and does not automatically bar subsequent issuance of an SCN where credible external or newly discovered evidence indicates suppression or evasion; however, extension of limitation periods for such proceedings requires a showing of deliberate concealment and judicial stay may be available in particular factual circumstances. (AI Summary)
The audit conclusion under ADT-02 functions as an intimation of findings at the end of the audit visit and does not automatically bar subsequent issuance of an SCN where credible external or newly discovered evidence indicates suppression or evasion; however, extension of limitation periods for such proceedings requires a showing of deliberate concealment and judicial stay may be available in particular factual circumstances. (AI Summary)