requisition

s.153A does not authorize de novo assessment. Non-pending assessments do not abate. Additions must be confined to search material

S. 153A provides that where a search is initiated u/s 132 the AO shall “assess or reassess the total income of six assessment years immediately preceding the assessment year” relevant to the previous year in which the search is conducted or requisition is made. The 1st Proviso states that the AO shall “assess or reassess the total income in respect of each assessment year falling within such six assessment years” while the 2nd Proviso states that the assessment o..
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Computation of undisclosed income in case no incriminating document was found during search

Searches conducted by the Income Department are important means for unearthing black money. However, under the scheme before insertion of special procedure for assessment of search cases, valuable time is lost in trying to relate the undisclosed incomes to the different years. Tax evaders generally manage to divert the focus to procedural and legal issues and often invent new evidence to explain undisclosed income. By the time search r
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