The HC set aside the impugned notice issued under section 148 and remanded the matters to the respective Assessing Officers (AOs) for fresh consideration. The AOs are directed to evaluate each show-cause notice individually, apply governing SC and HC precedents, and determine jurisdictional authority, sanction requirements and the applicability of section 153C procedures where relevant. AOs must also examine and decide the question of surviving limitation period for reassessment for each noticee, and record reasoned, speaking orders addressing the impact of those precedents on the reassessment notices. The writ petitions are disposed subject to the aforesaid directions; further proceedings shall conform to the orders remanding the matters to the AOs.
The HC set aside the impugned notice issued under section 148 and remanded the matters to the respective Assessing Officers (AOs) for fresh consideration. The AOs are directed to evaluate each show-cause notice individually, apply governing SC and HC precedents, and determine jurisdictional authority, sanction requirements and the applicability of section 153C procedures where relevant. AOs must also examine and decide the question of surviving limitation period for reassessment for each noticee, and record reasoned, speaking orders addressing the impact of those precedents on the reassessment notices. The writ petitions are disposed subject to the aforesaid directions; further proceedings shall conform to the orders remanding the matters to the AOs.
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