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...
Under the second proviso to section 153A(1), initiation of a search abates a scrutiny assessment that remains pending for an assessment year within the prescribed search period. Accordingly, once the pending assessment for AY 2013-14 abated, the Assessing Officer had no jurisdiction to complete the regular assessment under section 143(3). The resulting assessment was non-est, and proceedings consequential upon it were also non-est.
Under the second proviso to section 153A(1), initiation of a search abates a scrutiny assessment that remains pending for an assessment year within the prescribed search period. Accordingly, once the pending assessment for AY 2013-14 abated, the Assessing Officer had no jurisdiction to complete the regular assessment under section 143(3). The resulting assessment was non-est, and proceedings consequential upon it were also non-est.
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