Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
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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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