Section 153A cannot be invoked if escaped income is not represented “in the form of asset”

Viraj Profiles Limited Vs DCIT (ITAT Mumbai)

ITAT extracted the fourth proviso to sec. 153A of the Act in the preceding paragraph. A careful perusal of the above said proviso would reveal that, in order to invoke the fourth proviso to sec.153A, it is required to be shown by the AO that

• the books of account or other documents or evidence in his possession reveal that the income which has escaped assessment for the relevant assessment year is “in the form of asset”
• the quantum of income so escaped amount to fifty lakhs or more in the relevant assessment year or in aggregate in the relevant assessment years.

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