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Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assessment procedure.
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A search initiated after 1 April 2021 does not itself bar a regular scrutiny assessment under Section 143(3). The post-search deeming provision for information suggesting escaped income permits reassessment under Sections 147 and 148 where original assessment proceedings have concluded or the time limit for scrutiny has expired. Where a return can still be processed or subjected to scrutiny within limitation, it may be addressed under Sections 143(1) or 143(3). A timely notice for scrutiny and timely assessment therefore remain valid despite the search. Participation in proceedings without objection also supported rejection of the jurisdictional challenge and consequential recovery action.
A search initiated after 1 April 2021 does not itself bar a regular scrutiny assessment under Section 143(3). The post-search deeming provision for information suggesting escaped income permits reassessment under Sections 147 and 148 where original assessment proceedings have concluded or the time limit for scrutiny has expired. Where a return can still be processed or subjected to scrutiny within limitation, it may be addressed under Sections 143(1) or 143(3). A timely notice for scrutiny and timely assessment therefore remain valid despite the search. Participation in proceedings without objection also supported rejection of the jurisdictional challenge and consequential recovery action.
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