Material found in the search may be a ground for notice and assessment under Section 153A of the Act but that would not efface or terminate all the consequence, which has arisen out of the regular assessment or reassessment

CIT v. Smt. Shaila Agarwal (Allahabad High Court) – he second proviso to Section 153A of the Act, refers    to abatement of the pending assessment or re-assessment proceedings. The word ‘pending’  does not operate any such interpretation, that wherever the appeal against such assessment or reassessment is pending, the same along with assessment or reassessment proceedings is liable to be abated. The principles of interpretation of taxing statutes do not permit the Court to interpret the Second Proviso to Section 153A in a m

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