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A Legal Dissection of Best Judgment Assessments in Tax Law, in the context of Sections 153A/153C in pursuance of search and seizure: Insights from a High Court Ruling

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..... rticle delves into a complex legal case that critically examines the application of best judgment assessment under Section 144 of the Income Tax Act, 1961, particularly in the context of Sections 153A/153C. The case highlights key judicial interpretations and procedural intricacies in tax assessments. 1. Best Judgment Assessment Under Section 144: At the heart of the case is the Assessing Officer .....

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..... ssessment years. The court's analysis focused on whether the Assessing Officer had justifiable grounds under these sections to extend the scope of assessment, which in turn would validate the application of Section 144. This aspect is crucial as it determines the legality of expanding the assessment beyond routine scrutiny, especially in light of findings from search operations. 3. The Critical R .....

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..... when leading to a best judgment assessment under Section 144. The court's examination of this aspect highlighted the need for concrete evidence to support extended assessments. 5. Compliance with DIN Requirements: An important procedural aspect raised in the case was the compliance with the requirement of a Document Identification Number (DIN). The judgment reaffirmed the legal necessity of inclu .....

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..... ent. In the present case the assessment order in question is quashed and set aside. This article offers a comprehensive overview of the legal issues, judicial analysis, and implications stemming from the High Court's decision, particularly emphasizing the nuanced application of best judgment assessment in tax law. Full Text: 2023 (9) TMI 335 - BOMBAY HIGH COURT
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