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Once a search under section 132 had been conducted before issuance of notices under section 148, the cases fell within the special search assessment regime and the Assessing Officer had to proceed only under that overriding mechanism for the relevant six assessment years. The Tribunal applied Kabul Chawla and State Bank of India to hold that invoking the ordinary reassessment provisions under sections 147/148 after the search was contrary to the statutory scheme, rendering the notices and consequential assessments void ab initio. The reassessment notices and orders were therefore quashed as without jurisdiction.
Once a search under section 132 had been conducted before issuance of notices under section 148, the cases fell within the special search assessment regime and the Assessing Officer had to proceed only under that overriding mechanism for the relevant six assessment years. The Tribunal applied Kabul Chawla and State Bank of India to hold that invoking the ordinary reassessment provisions under sections 147/148 after the search was contrary to the statutory scheme, rendering the notices and consequential assessments void ab initio. The reassessment notices and orders were therefore quashed as without jurisdiction.
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