Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reassessment proceedings were upheld as within limitation because the section 148A(b) notice was issued on 31.03.2022, and the time allowed for the assessee's response had to be excluded under the third proviso to section 149, with the balance period extended under the fourth proviso. As the reply was filed on 21.04.2022, the Assessing Officer had time until 21.05.2022 to pass the section 148A(d) order, so the 28.04.2022 order and consequential section 148 notice were timely. The Court also rejected the challenge that entries in books or survey material were not an "asset" under section 149(1)(b), holding the definition inclusive and the later amendment clarificatory.
Reassessment proceedings were upheld as within limitation because the section 148A(b) notice was issued on 31.03.2022, and the time allowed for the assessee's response had to be excluded under the third proviso to section 149, with the balance period extended under the fourth proviso. As the reply was filed on 21.04.2022, the Assessing Officer had time until 21.05.2022 to pass the section 148A(d) order, so the 28.04.2022 order and consequential section 148 notice were timely. The Court also rejected the challenge that entries in books or survey material were not an "asset" under section 149(1)(b), holding the definition inclusive and the later amendment clarificatory.
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