Pr. Commissioner Of Income Tax Central 3 vs Abhisar Buildwell P. Ltd.

The Supreme Court addressed the issue of whether the waiver of limitation under section 150(2) applies to reassessment proceedings initiated under sections 148, 153A, or 153C, especially in cases where assessments were passed without incriminating material found during searches. The court clarified that the law permits initiating fresh reassessment proceedings based on findings from search assessments, even if the original assessments were not based on incriminating material. The judgment emphasizes that the scope of limitation waivers and reassessment procedures must be understood in the context of search and non-search assessments. The court's decision provides guidance on the applicability of limitation waivers to reassessment proceedings in tax law.