Part I -- Reassessment Proceedings and Assessment in Search and Survey Cases Under New Regime |
1
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| Section A -- Overview of New Reassessment Regime and Comparison with Old Regime |
2
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| 1 Reassessment Provisions Effective from 1-4-2021 |
3
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| 2 Comparison between Old Procedure and New Procedure for Reassessment |
17
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| 3 Concepts Given Go-by Under New Procedure |
23
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| 4 Significant Changes in Reassessment Scheme in Comparison to Old Law |
28
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| 5 Decisions Under Old Law and Their Applicability in New Law |
42
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| Section B -- Reassessment Procedure Effective from 1-4-2021 |
47
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| 6 Scheme for Reassessment Under New Section 147 |
48
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| 7 Income Chargeable to Tax -- Scope of |
68
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| 8 Exempt Incomes and Reopening |
77
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| 9 Cash Deposits/Withdrawal -- Whether Constitute Income Chargeable to Tax |
82
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| 10 Income Escaped Assessment -- Meaning and Scope of |
94
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| 11 Jurisdiction under Section 147 in Case of Assessee Only |
101
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| 12 Reassessment of Issues Coming into Notice of Assessing Officer Subsequently |
111
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| 13 Scope of Reassessment Proceedings under Section 147 |
131
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| Section C -- Procedure Under Section 148A and Notice Under Section 148 |
137
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| 14 Conducting Inquiry and Providing Opportunity of Hearing before Issuance of Show-Cause Notice under Section 148 |
138
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| 15 New Scheme of Section 148A and Judgments of High Courts |
163
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| 16 Notice under Section 148 |
186
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| 17 Information as Basis for Reopening |
199
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| 18 Deemed Information Under Explanation 2 to Section 148 |
224
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| 19 Checklist for Notices Issued under Section 148A/148 |
236
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| 20 Challenging Notice under Section 148/148A Invoking Writ -- Principles Regarding Writ Jurisdiction |
253
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| 21 Challenging Notice under Section 148/148A in Writ |
268
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| 22 Notices under Section 148 under Unamended Law -- Position Post Supreme Court Verdict |
277
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| 23 Issues Concerning New Scheme of Reassessment |
299
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| Section D -- Time Limit for Issuance of Notice and Reassessment |
349
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| 24 Time Limit for Reopening of Assessment |
350
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| 25 Notice Where Time Limit as per Section 149(1)(b) -- Issues Regarding |
368
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| 26 Issue and Service of Notice -- The Framework Regarding |
384
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| 27 Notice by E-Mail |
387
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| 28 Issue Versus Service of Notice |
394
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| 29 Issues Regarding Service of Notice |
425
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| 30 Notice under Section 148 to Different Entities |
443
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| 31 Notice to Dead Person |
452
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| 32 Notice to Non-Existent Company |
465
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| 33 Validity of Notice |
477
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| 34 Reassessment Proceedings and Requirement of Issue of Notice under Section 143(2) |
499
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| 35 Approvals/Sanction for Issuance of Notice and for Various Process Under the New Regime |
521
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| 36 Faceless Reassessment Proceedings |
531
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| 37 Time Limit for Completion of Reassessment |
544
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| Section E -- Assessment in Search and Survey Cases Where Action Taken on or After 1-4-2021 |
555
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| 38 Search Under Income Tax Law |
556
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| 39 Procedure for Assessment Where Search or Requisition Initiated on or after 1-4-2021 |
561
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| 40 Whether New Claim Can be Made in Search Assessments Under New Regime |
592
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| 41 Claim of Loss in Reassessment Proceedings |
598
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| 42 Survey Under Income Tax Law |
605
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| 43 Assessment Procedure in Case of Survey Conducted on or after 1-4-2021 |
611
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| Section F -- Other Issues |
616
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| 44 Reassessment in Pursuance of Order on Appeal |
617
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| 45 Claim of Fresh Reliefs, Deductions or Rebates in Reassessment Proceedings |
629
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| 46 New Reassessment Procedure and Change of Opinion |
636
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| 47 Reopening of Assessment -- Whether Permissible on the Basis of Report of Valuation Officer |
648
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| 48 Furnishing of Updated Return Vis-a-Vis Reassessment Proceedings |
652
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Part II -- Reassessment Procedure as Existed Upto 31-3-2021 |
657
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| Section A -- Reassessment Basics and Principles |
658
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| 49 Reassessment Provisions As Existed Upto 31-3-2021 |
659
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| 50 Income Escaping Assessment in Context of Earlier Provision |
665
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| 51 Scope of Reassessment As Judicially Noticed Under Pre-Amended Scheme |
697
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| 52 Concept of Reason to Believe |
714
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| 53 Jurisdiction under Section 147 When Assessment Proceedings Pending |
764
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| 54 Reopening on Change of Opinion |
776
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| 55 Assessment under Section 143(1) and Change of Opinion |
790
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| 56 Illustrations of Change of Opinion or Otherwise |
800
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| 57 Reopening on Basis of Audit Objection |
848
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| 58 Reopening on Basis of DVO’s Report |
861
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| 59 Reopening on Basis of Information from Investigation Wing |
869
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| 60 Reopening of Assessment Completed under Section 143(3) or Section 147 |
886
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| 61 Reopening on Issue Other Than That Specified in Notice |
911
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| 62 Full and True Disclosure |
934
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| 63 Illustrative Case Laws on ‘Full and True Disclosure’ |
964
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| 64 Validity of Reopening |
1004
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| 65 Powers and Jurisdiction of Assessing Officer |
1086
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| Section B -- Notice for Reassessment |
1099
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| 66 Issue of Notice for Reassessment Under Earlier Section 148 |
1100
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| 67 Recording of Reasons |
1126
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| 68 Furnishing of Reasons to Assessee and Objections of Assessee |
1145
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| 69 Time Limit for Issuance of Notice under Section 148 |
1164
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| 70 Sanction for Issue of Notice under Section 148 |
1172
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| 71 Challenge to Action for Reassessment in Writ Petition |
1194
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