Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported ...
Equivalent-value attachment can reach pre-existing assets, but jointly owned property remains protected beyond the accused's attributable proceeds of ...
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
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