Search Assessment Quashed: Why IT Act Section 153A Requires an Actual Search on the Assessee

Sumangal Jewels Pvt. Ltd. Vs DCIT (ITAT Kolkata) If You Didn’t Search Me, You Can’t Assess Me – ITAT Slams Illegal 153A This case deals with the very foundation of search assessments u/s 153A &  whether the Revenue can validly invoke this provision without actually conducting a search on Assessee. Department claimed that a search u/s 132 was conducted on 01.12.2015, &  based on that, issued notices &  completed assessments u/s 153A r.w.s. 143(3). AO made heavy additions towards unexplained share capital (₹1.22 crore) &  unexplained expenses (₹11.85 lakh). However,...