Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
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The article addresses the scope of the Fourth Proviso to Section...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the threshold.
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The article addresses the scope of the Fourth Proviso to Section 153A, holding that the proviso permits extended ten-year inquiries only where the assessing officer's recorded satisfaction reasonably shows escaped income or assets that 'amount to or are likely to amount to' the statutory threshold; provisional satisfaction at the notice stage must rest on a fair assessment of available material and not mere ipse dixit. On the facts, the recorded satisfaction related to the searched year and aggregate amounts for the extended years fell below the threshold, so initiation of assessments for the extended years was quashed subject to liberty to reopen if a fresh properly recorded satisfaction is formed.
The article addresses the scope of the Fourth Proviso to Section 153A, holding that the proviso permits extended ten-year inquiries only where the assessing officer's recorded satisfaction reasonably shows escaped income or assets that 'amount to or are likely to amount to' the statutory threshold; provisional satisfaction at the notice stage must rest on a fair assessment of available material and not mere ipse dixit. On the facts, the recorded satisfaction related to the searched year and aggregate amounts for the extended years fell below the threshold, so initiation of assessments for the extended years was quashed subject to liberty to reopen if a fresh properly recorded satisfaction is formed.
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