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 ...
Reassessment u/s 147 - Department had collected certain documents and materials in search which were before the AO at the time of framing assessment - non utilization of such material by AO for any reason cannot be considered as failure to disclose truly and fully all material facts by assessee - impugned notice is set aside
Reassessment u/s 147 - Department had collected certain documents and materials in search which were before the AO at the time of framing assessment - non utilization of such material by AO for any reason cannot be considered as failure to disclose truly and fully all material facts by assessee - impugned notice is set aside
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