Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reassessment u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
Reassessment u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
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