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    <title>TIME LIMIT FOR COMPLETION OF ASSESSMENT FROM THE DATE OF SPECIAL AUDITOR’S REPORT UNDER INCOME TAX ACT, 1961</title>
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    <description>Special audit directions require prior Commissioner approval and a reasonable opportunity of hearing; the nominated accountant must supply a prescribed report and the statutory due date for that report governs the extension of the assessment limitation period. Proof that an assessment order was issued within the extended limitation period depends on objective evidence of issuance beyond the tax authority&#039;s control, particularly contemporaneous dispatch records, and absence of such proof undermines claims that assessments were within time.</description>
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      <description>Special audit directions require prior Commissioner approval and a reasonable opportunity of hearing; the nominated accountant must supply a prescribed report and the statutory due date for that report governs the extension of the assessment limitation period. Proof that an assessment order was issued within the extended limitation period depends on objective evidence of issuance beyond the tax authority&#039;s control, particularly contemporaneous dispatch records, and absence of such proof undermines claims that assessments were within time.</description>
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