https://www.taxtmi.com/caselaws?id=793666 A tax settlement scheme exclusion must be applied strictly to its express terms: the search-based bar under section 96(a)(i) applies only where the reassessment is founded on a search under sections 132 or 132A. Where earlier proceedings under section 153C had been dropped and the reassessment proceeded instead on survey material under section 133A, the exclusion could not be extended by implication. Search and survey are distinct proceedings, and the scheme contained no express bar for survey-based reassessments. The rejection of the declarations was therefore unjustified, and the writ petitions succeeded with directions to accept the declarations and issue the required forms. en-us Tue, 09 Jun 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793666 A tax settlement scheme exclusion must be applied strictly to its express terms: the search-based bar under section 96(a)(i) applies only where the reassessment is founded on a search under sections 132 or 132A. Where earlier proceedings under section 153C had been dropped and the reassessment proceeded instead on survey material under section 133A, the exclusion could not be extended by implication. Search and survey are distinct proceedings, and the scheme contained no express bar for survey-based reassessments. The rejection of the declarations was therefore unjustified, and the writ petitions succeeded with directions to accept the declarations and issue the required forms. Case-Laws Income Tax Tue, 09 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793666