Reassessment cannot proceed on the assumption that no return was...

Reassessment cannot proceed on the assumption that no return was filed once the assessee has in fact filed a return pursuant to notice under section 142(1); a later corrigendum that merely records the return without correcting the basis does not cure the foundational error, so the draft assessment order requires reconsideration and fresh proceedings may be taken in accordance with law. The text also notes that, for computing reassessment limitation under section 153(2), the time spent in a writ petition with interim protection before expiry of the period may be excluded, allowing the Department to proceed afresh after the impugned order is set aside.