https://www.taxtmi.com/caselaws?id=767881 Reassessment notices issued on or after 1 April 2021 fall under the substituted reassessment framework, requiring enquiry, an opportunity to respond, and consideration of the taxpayer's reply before forming a view that income escaped assessment. Failure to follow that procedure renders the reassessment jurisdictionally invalid. Where a return is filed in response to a reassessment notice and assessment is made through scrutiny, notice under section 143(2) is mandatory. Complete non-issuance of that notice cannot be cured by section 292BB and renders the reassessment void from inception. Reliance on investigation-wing information also requires independent application of mind under the amended regime. en-us Fri, 21 Mar 2025 00:00:00 +0530 Fri, 18 Sep 2026 15:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767881 Reassessment notices issued on or after 1 April 2021 fall under the substituted reassessment framework, requiring enquiry, an opportunity to respond, and consideration of the taxpayer's reply before forming a view that income escaped assessment. Failure to follow that procedure renders the reassessment jurisdictionally invalid. Where a return is filed in response to a reassessment notice and assessment is made through scrutiny, notice under section 143(2) is mandatory. Complete non-issuance of that notice cannot be cured by section 292BB and renders the reassessment void from inception. Reliance on investigation-wing information also requires independent application of mind under the amended regime. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767881