DCIT v. Pallavi Mishra (Smt.) (2021) 191 ITD 13 (Jaipur)(Trib.)

S. 153A : Assessment-Search-Protective assessment-Protective assessment cannot be converted in to substantive assessment without invoking jurisdiction under section 147 of the Act. [S. 143 (3) 147, 154, 245D(4)]

Held that Protective assessment cannot be converted in to substantive assessment without invoking jurisdiction under section 147 of the Act.  Once an assessment has been framed by Assessing Officer, he becomes functus officio and whenever Assessing Officer wishes to modify and/or enhance assessment, he is required to reassume jurisdiction under Act after satisfying conditions as contained in section 154 or section 147 of the Act. (AY. 2013-14)