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

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..... open a case under Section 147 of the Income Tax Act , seeking a waiver of the limitation period under Section 150(2) , following the quashing of assessments under Sections 153A and 153C in a Judgement as reported in [ 2023 (4) TMI 1056 - SUPREME COURT] . This commentary will analyze the legal principles, the application of these principles in the case, and conclude with the Supreme Court&# .....

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..... d 153C - Assessment in Case of Search or Requisition : These sections deal with assessment and reassessment procedures when a search is conducted. The quashing of assessments under these sections is a critical aspect of this case, influencing the applicability of Section 147 . In the present case, the Revenue sought clarification from the Supreme Court on whether, following the quashing .....

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..... it did not enter into the merits of the application and that the review application should be decided on its own merits in accordance with the law. This decision underscores the importance of adhering to procedural norms and the necessity of detailed judicial scrutiny in matters involving complex questions of law, particularly in the realm of income tax assessments. Conclusion The Supreme .....

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