Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reassessment notices issued more than three years after the relevant assessment year require approval under section 151(ii) from the specified senior authorities; approval by a Principal Commissioner is described as incompetent. The notes state that a later proviso to section 151 cannot retrospectively exclude the reply period under section 148A(b), resulting in invalidation of the reassessment notice and consequential reassessment for the stated year. They further address section 80P deduction: after condonation of delayed return filing, the deduction claim, including interest earned from a co-operative bank, is to be reconsidered by the Assessing Officer, with interest income directed to be allowed if earned from that bank.
Reassessment notices issued more than three years after the relevant assessment year require approval under section 151(ii) from the specified senior authorities; approval by a Principal Commissioner is described as incompetent. The notes state that a later proviso to section 151 cannot retrospectively exclude the reply period under section 148A(b), resulting in invalidation of the reassessment notice and consequential reassessment for the stated year. They further address section 80P deduction: after condonation of delayed return filing, the deduction claim, including interest earned from a co-operative bank, is to be reconsidered by the Assessing Officer, with interest income directed to be allowed if earned from that bank.
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