https://www.taxtmi.com/caselaws?id=463659 A reassessment under section 153C based on search material was interfered with because the satisfaction note was recorded belatedly and the assessee was not given a meaningful opportunity before the best judgment assessment was finalised. Although the proceedings were not barred by limitation, the delay after the return was filed and the manner of completion showed that fairness required a further hearing. The assessment order was therefore treated as a show cause notice, and fresh assessment was directed after giving the assessee an opportunity to explain its case. en-us Tue, 12 Mar 2024 00:00:00 +0530 Wed, 10 Sep 2025 19:00:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463659 A reassessment under section 153C based on search material was interfered with because the satisfaction note was recorded belatedly and the assessee was not given a meaningful opportunity before the best judgment assessment was finalised. Although the proceedings were not barred by limitation, the delay after the return was filed and the manner of completion showed that fairness required a further hearing. The assessment order was therefore treated as a show cause notice, and fresh assessment was directed after giving the assessee an opportunity to explain its case. Case-Laws Income Tax Tue, 12 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463659