Section 153A: Completed assessment cannot be interfered in absence of discovery of incriminating material during search

ACIT Vs M/s. Samor Properties Pvt. Ltd. (ITAT Ahmedabad) It is not the case of the appellant that any incriminating material in respect of the assessment year under consideration was found during the course of search. At the relevant time when the notice came to be issued under section 153A of the Act, the assessee filed its return of income. Much later, at the fag end of the period within which the order under section 153A of the Act was to be made, in other words, when the limit for framing the assessment as provided under section 153 was about to expire, the notice has been issued in the p...