https://www.taxtmi.com/caselaws?id=799373 For searches initiated on or after 1 April 2021, assessment of a year preceding the search year falls within reassessment jurisdiction and requires a notice under section 148. A search is deemed information suggesting income escapement, while the exclusion from the preliminary procedure under section 148A does not remove the requirement of valid initiation under section 148. Statutory limitations, approvals and order requirements operate independently; approval for a subsequent order cannot cure the absence of a section 148 notice. Administrative scrutiny guidelines and participation in proceedings under sections 143(2) and 143(3) cannot confer jurisdiction. An assessment initiated only under those provisions is legally unsustainable. en-us Tue, 18 Aug 2026 00:00:00 +0530 Mon, 21 Sep 2026 08:57:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799373 For searches initiated on or after 1 April 2021, assessment of a year preceding the search year falls within reassessment jurisdiction and requires a notice under section 148. A search is deemed information suggesting income escapement, while the exclusion from the preliminary procedure under section 148A does not remove the requirement of valid initiation under section 148. Statutory limitations, approvals and order requirements operate independently; approval for a subsequent order cannot cure the absence of a section 148 notice. Administrative scrutiny guidelines and participation in proceedings under sections 143(2) and 143(3) cannot confer jurisdiction. An assessment initiated only under those provisions is legally unsustainable. Case-Laws Income Tax Tue, 18 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799373