Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Reassessment founded solely on material seized during a search of group entities is impermissible where proceedings should have been initiated against another person under the special search-assessment scheme. The Assessing Officer of the searched person must record and transmit a satisfaction note before seized incriminating material may be used against another assessee. Reassessment under sections 147 and 148 requires independently obtained material and cannot rest exclusively on search material. In the absence of a satisfaction note and any independent material, the reassessment notice and order under section 148A(d) were quashed.
Reassessment founded solely on material seized during a search of group entities is impermissible where proceedings should have been initiated against another person under the special search-assessment scheme. The Assessing Officer of the searched person must record and transmit a satisfaction note before seized incriminating material may be used against another assessee. Reassessment under sections 147 and 148 requires independently obtained material and cannot rest exclusively on search material. In the absence of a satisfaction note and any independent material, the reassessment notice and order under section 148A(d) were quashed.
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