Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Reassessment founded solely on investigation material and statements already available during prior search assessment and revision proceedings constitutes reliance on stale material and a change of opinion. Repackaging existing information does not create fresh jurisdiction to reopen assessment. Where lender-company confirmations are obtained before issuing the reassessment notice but their responses are not addressed, the reopening lacks an adequate basis. Approval based on the same pre-existing material is mechanical and does not cure the jurisdictional defect. The reassessment proceedings and consequential additions were therefore deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
