Seized-material nexus under Section 153C: AO must form reasoned satisfaction before reopening assessments for specific years. Section 153C requires the Assessing Officer to form a reasoned satisfaction that seized material during a search has a bearing on an assessee's total ... Summary
Seized-material nexus under Section 153C: AO must form reasoned satisfaction before reopening assessments for specific years.
Section 153C requires the Assessing Officer to form a reasoned satisfaction that seized material during a search has a bearing on an assessee's total income before initiating assessments; mere discovery is insufficient, and the AO must identify specific assessment years, map incriminating material year-wise, and record reasons to justify abatement or reopening.
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