Search-related reassessment notices require independent prior approval, and an inapplicable section 148A process cannot cure jurisdictional defects.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Search-related information concerning alleged non-genuine purchases must be addressed through the statutory reassessment route applicable where material is found in another person's search. The ordinary procedure under section 148A cannot displace that route. Approval for an order under section 148A(d) does not substitute for the independent prior approval required before issuing a notice under section 148. Compliance with the prescribed jurisdictional procedure is mandatory, not procedural; non-compliance creates a foundational jurisdictional defect and renders the reassessment notice and consequential assessment liable to be quashed without determination of the underlying addition.....