Willful failure to file a return after notice triggers criminal prosecution; searches or requisitions can shift prosecution to an alternate provision.

Prosecution under Section 276CCC applies where a person wilfully fails to furnish a return of total income in response to a notice under Section 158BC(a); however, if a search under Section 132 or requisition under Section 132A is initiated after 31-05-2003, prosecution for failure to furnish in response to the assessing officer's notice proceeds under Section 276CC instead.

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