Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is not a valid satisfaction, as satisfaction u/s 158BD has to be recorded by the AO of the searched person and not by the AO of the other person i.e. assessee.
Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is not a valid satisfaction, as satisfaction u/s 158BD has to be recorded by the AO of the searched person and not by the AO of the other person i.e. assessee.
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