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...
Post-search reassessment for assessment years preceding a search initiated after 31 March 2021 must be commenced under the reassessment framework in sections 147 and 148. Explanation 2(i) to section 148 deems such a search to be information suggesting income escapement, while exemption from the preliminary procedure under section 148A in specified search cases does not remove the mandatory section 148 notice. Compulsory scrutiny selection and a notice under section 143(2) issued under administrative guidelines cannot confer reassessment jurisdiction. Later approval or taxpayer participation cannot cure a jurisdictional defect caused by failure to issue the required notice.
Post-search reassessment for assessment years preceding a search initiated after 31 March 2021 must be commenced under the reassessment framework in sections 147 and 148. Explanation 2(i) to section 148 deems such a search to be information suggesting income escapement, while exemption from the preliminary procedure under section 148A in specified search cases does not remove the mandatory section 148 notice. Compulsory scrutiny selection and a notice under section 143(2) issued under administrative guidelines cannot confer reassessment jurisdiction. Later approval or taxpayer participation cannot cure a jurisdictional defect caused by failure to issue the required notice.
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TaxTMI 
TaxTMI 
of 4879 
