Directory time limit for belated return filing after best judgment assessment displaces provisional assessment.

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....The period for filing a return after a best judgment assessment was treated as directory, not mandatory. Once a belated return is filed, the provisional assessment made for non-filing does not survive and the matter must proceed in the regular course for further assessment for the year. On that basis, the impugned best judgment assessment order was quashed and the respondent was directed to complete further assessment in accordance with law.....