Pre reopening inquiry and show cause under section 148A require prior approval, opportunity to reply, and timely decision. Before issuing a notice under section 148 the Assessing Officer must, with prior approval of the specified authority where required, conduct any necessary inquiry, serve a show cause notice affording at least seven days and not more than thirty days to reply (subject to extension), consider the reply, and decide with prior approval within one month from the end of the month in which the reply is received or the reply period expires; section 148A excludes cases involving searches or requisitions on or after 1 April 2021 and certain seized or requisitioned materials relating to the assessee; remedies by appeal are barred, though writs may lie for natural justice breaches.
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Provisions expressly mentioned in the judgment/order text.
Pre reopening inquiry and show cause under section 148A require prior approval, opportunity to reply, and timely decision.
Before issuing a notice under section 148 the Assessing Officer must, with prior approval of the specified authority where required, conduct any necessary inquiry, serve a show cause notice affording at least seven days and not more than thirty days to reply (subject to extension), consider the reply, and decide with prior approval within one month from the end of the month in which the reply is received or the reply period expires; section 148A excludes cases involving searches or requisitions on or after 1 April 2021 and certain seized or requisitioned materials relating to the assessee; remedies by appeal are barred, though writs may lie for natural justice breaches.
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