Parallel reassessment on identical search-assessment additions was quashed because it would directly affect pending tax appeals.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reassessment based on additions identical to those made in an original search assessment cannot proceed while tax appeals challenging that assessment remain pending, where the original appellate authority considered the additions on merits as well as technical grounds. The High Court found that parallel reassessment would directly affect the pending appeals. Precedent permitting reassessment after an assessment was annulled solely on a technical ground did not apply. The reopening notice and consequential reassessment orders were quashed; the merits of the additions remain to be decided in the pending tax appeals.....