https://www.taxtmi.com/manuals?id=5936 The text explains that a legal fiction (expressed by 'deemed') treats a thing as existing for a definite purpose and must be limited to that purpose; courts give full effect to the fiction by assuming incidental facts and working out consequences only to their logical extent. As an illustration, earlier reassessment notices were reclassified as show-cause notices under the substituted procedural regime to enable continuity of reassessment proceedings, and that reclassification was confined to the temporal window and purpose necessary to maintain that continuity. en-us Tue, 26 Nov 2024 12:31:00 +0530 Wed, 12 Feb 2025 15:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=5936 The text explains that a legal fiction (expressed by 'deemed') treats a thing as existing for a definite purpose and must be limited to that purpose; courts give full effect to the fiction by assuming incidental facts and working out consequences only to their logical extent. As an illustration, earlier reassessment notices were reclassified as show-cause notices under the substituted procedural regime to enable continuity of reassessment proceedings, and that reclassification was confined to the temporal window and purpose necessary to maintain that continuity. Manuals Income Tax Tue, 26 Nov 2024 12:31:00 +0530 https://www.taxtmi.com/manuals?id=5936