Reassessing Income under Section 147 Post-Quashment of Sections 153A/153C: The Waiver of Limitation under Section 150(2)

Reopening assessments under Section 147 requires proper review when Section 150(2) waiver is contested, not clarification.

Reopening of assessments under Section 147 concerns whether the Assessing Officer has a reason to believe that income has escaped assessment and is subject to procedural safeguards including issuance of a statutory notice. Where prior assessments made in consequence of a search under provisions for search-based assessment were quashed, the question arises whether fresh proceedings may be initiated for income not arising from incriminating material found in the search and whether the limitation period can be waived under Section 150(2) to permit issuance of a notice for reassessment.