TMI BlogA 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 RulingX X X X Extracts X X X X X X X X Extracts X X X X ..... ction: This article 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 c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns mandate a thorough reassessment for specified assessment 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sections 153A / 153C , require substantial justification, especially 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 Ident ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the rigorous judicial scrutiny applied to the processes of tax assessment and reassessment. 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 i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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