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...
Section 153C treats the recording of satisfaction, or receipt of...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statutory route.
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Section 153C treats the recording of satisfaction, or receipt of seized records by the Assessing Officer of a non-searched person, as that person's deemed search date. Where that event occurs after 1 April 2021, proceedings under section 153C(3) are unavailable and reassessment under section 147 is the applicable route. A consolidated satisfaction note must also identify assessee-specific adverse material and explain its nexus to income alleged to have escaped assessment; generic references to digital devices or electronic evidence do not satisfy this requirement.
Section 153C treats the recording of satisfaction, or receipt of seized records by the Assessing Officer of a non-searched person, as that person's deemed search date. Where that event occurs after 1 April 2021, proceedings under section 153C(3) are unavailable and reassessment under section 147 is the applicable route. A consolidated satisfaction note must also identify assessee-specific adverse material and explain its nexus to income alleged to have escaped assessment; generic references to digital devices or electronic evidence do not satisfy this requirement.
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