Pre-registration safeguards do not require a hearing or preliminary inquiry before corruption FIR registration where cognizable offences are disclosed...
Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
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Searches conducted before 1 April 2021 require assessment or reassessment through the search-assessment framework under sections 153A/153C. Incriminating material found in such a search cannot subsequently support reassessment jurisdiction under sections 147/148 or proceedings under section 148A. Those reassessment provisions remain available only where information is independently obtained after the search and statutory conditions are met. Reassessment notices and orders founded solely on pre-1 April 2021 search material are therefore without jurisdiction and liable to be quashed.
Searches conducted before 1 April 2021 require assessment or reassessment through the search-assessment framework under sections 153A/153C. Incriminating material found in such a search cannot subsequently support reassessment jurisdiction under sections 147/148 or proceedings under section 148A. Those reassessment provisions remain available only where information is independently obtained after the search and statutory conditions are met. Reassessment notices and orders founded solely on pre-1 April 2021 search material are therefore without jurisdiction and liable to be quashed.
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