Mere reference of assessee’s name in the statement under section 132(4) is not sufficient to invoke the proceedings under section 158BD

RELEVANT PARAGRAPH 5. The assessee was subjected to search assessment, whereupon additions were made, which included disallowance of interest expenditure Rs.54,1800/- ; addition for unexplained cash credit Rs.10,500/-, and another disallowance of claim of set off of business loss Rs.18,698/-; totalling Rs.83,378/-. The assessee contended before the AO that the disallowance of interest expenditure on bank loan was only a technical addition. The assessee did not appeal against the same because of the smallness of the amount. Coming to the next addition of cash credit, it was stated that this was...