CIT v. Anil Kumar Bhatia

352 ITR 493High Court2013#118 most cited

What is CIT v. Anil Kumar Bhatia authority for?

Under Section 153A, the Assessing Officer holds broad jurisdiction to compute the total income for the six assessment years preceding the year of search, without statutory fetters or limitations on this period.

537

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Anil Kumar Bhatia · Section 153A · search assessment · jurisdiction of AO · six assessment years · preceding year of search · Section 132 · Section 148 · unfettered power

Also reported as

24 Taxmann.com 98211 Taxmann 453

Sections most often in play

Section 132Section 148Section 153ASection 143(3)Section 147Section 139(1)Section 143(1)Section 69A
Read the full judgment

Issues it is cited on

section 153aofcasus omissussection 153(1)(a)section 153(1)sanctioning authoritysection 153a(1)(b)section 153a(1)non application of mindsection 153bsection 132asearch assessmentsection 132(1)

Judgments citing CIT v. Anil Kumar Bhatia

M/S TRIPLE S STOCK AND SHARES PVT LTD vs. ITO WARD-16(4) NEW DELHI

ITA/164/2026HC Delhi13 Mar 2026

Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA

Section 143(3)Section 153A

…for the Department-respondent accepts the notice. 3. Since the controversy in hand lies in a very narrow compass and the issue is covered by judgment of this Court rendered in the case of Commissioner of Income Tax v. Anil Kumar Bhatia reported in (2013) 352 ITR 493 so also by the judgment of Hon’ble the Supreme Court This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 18/03/2026 at 15:43:56 ITA 164/2026…

PARAM PROPERTT DEVLOPER,AMBERNATH vs. ACIT, CENTRAL CIRCLE-2, THANE, THANE

ITA 3243/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarit(Ss)A/3241/Mum/2025 (A.Y. 2016-17) It(Ss)A/3242/Mum/2025 (A.Y. 2017-18) It(Ss)A/3243/Mum/2025 (A.Y. 2020-21) Param Property Developers V/S. Assistant Commissioner Of Plot No. 30, Jivandeep बनाम Income Tax, Central Circle Apartment, Station Road, Ambarnath(E), Thane 421501, Maharashtra 2,Thane, Ashar It Park, 6Th Floor, Wagale Industrial Estate, Thane- 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfp9248G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Pride Infrastructure It(Ss)A/3309/Mum/2025 (A.Y. 2014-15) It(Ss)A/3310/Mum/2025 (A.Y. 2015-16) V/S. Assistant Commissioner Of Plot No. 34, Ketan Bhavan, बनाम Income Tax, Central Circle Suryoday Chs Ltd., Station Road, Ambarnath(E), Thane 421 501, Maharashtra 2,Thane, Ashar It Park, 6Th Floor, Wagale Industrial Estate, Thane- 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aamfp3255G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Page | 2

Section 132Section 143(3)

…IN THE INCOME-TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER IT(SS)A/3241/MUM/2025 (A.Y. 2016-17) IT(SS)A/3242/MUM/2025 (A.Y. 2017-18) IT(SS)A/3243/MUM/2025 (A.Y. 2020-21) Param Property Developers v/s. Assistant Commissioner of Plot No. 30, Jivandeep बनाम Income Tax, Central Circle Apartment, Station Road, Ambarnath(E), Thane 421501, Maharashtra 2,Thane, Ashar IT Park, 6th Floor, Wagale Industrial Estate, Thane- 400 604, Maharashtra स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AALFP9248G Appellant/अपीलार्थी .. Respondent/प्रतिवाद…

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.No.987/PUN/2025 (Assessment Year : 2014-15) DCIT, Circle-1, M/s. Shree Sai Properties, Nashik 2 Nilayam Apartment, Opp. Vasant Market, Canada Corner, vs. Nashik - 422001 PAN : ABSFS3624H (Appellant) (Respondent) For Assessee : Shri Subodh Ratnaparkhi, CA For Revenue : Shri Amit Bobde, CIT Date of Hearing : 20.11.2025 Date of Pronouncement : 27.01.2026 ORDER PER DR.MANISH BORAD, AM This appeal at the instance of the Revenue for the Assessment Year 2014-15 is dir…

INCOME TAX OFFICER, PUNE vs. SAGAR CONSTRUCTION COMPANY, PUNE

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

…al assessment procedure is to be understood as merely dispensing with procedural aspect; search assessment can be reopened under section 147. 27. Referring to the decision of Hon’ble Delhi High Court in the case of CIT vs. Anil Kumar Bhatia reported in (2013) 352 ITR 493 (Del), he submitted that the Hon’ble High Court in the said decision has held that post search reassessment in respect of all 6 years can be made even if original returns are already processed u/s 143(1)(a) and the Assessing Officer has power u/s 153A to make assessment for all six years and compute total income of assessee, including undisclosed…

SHALIGRAM INFRA PROJECTS LLP ( LTD. LIABILITY PARTNERSHIP),AHMEDABAD vs. THE JCIT (OSD), CENTRAL CIRCLE-2(2), AHMEDABAD

Appeals are partly allowed

ITA 233/AHD/2021[2018-19]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2018-19

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarit(Ss)A No.167/Ahd/2021 Asstt.Year : 2017-18 & Asst.Year : 2018-19 Shaligram Infra Projects Llp Vs. The Jcit (Osd) 4Th Floor, Office No.401-402 Central Cir.2(2) B/H. Dishman House Ahmedabad. Opp: Sankalp Grace Ii, Ambli Ahmedabad. Pan: Acpfs 7047 A It(Ss)A No.194,195 & 196/Ahd/2021 Asstt.Year : 2015-16, 2016-17 & 2017-18 & Asst.Year : 2018-19 The Jcit (Osd) Vs. Shaligram Infra Projects Llp Central Cir.2(2) 4Th Floor, Office No.401-402 Ahmedabad. B/H. Dishman House Opp: Sankalp Grace Ii, Ambli Ahmedabad.

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Rignesh Das, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153A

…lized through section 153C, is therefore not in consonance with the scheme of the Act. 11. We have also carefully considered the reliance placed by the Revenue on the decisions of the Hon’ble Delhi High Court in CIT v. Anil Kumar Bhatia [2012] 211 Taxman 453/352 ITR 493 (Delhi) and the Hon’ble Kerala High Court in E.N. Gopakumar v. CIT (Central) [2016] 75 taxmann.com 215/390 ITR 131 (Ker.). Both these judgments, though rendered in the context of The DCIT, Cent.Cir.Vs.Shaligram Infra Projects LLP (6 Appeals) 12 section 153A, are distinguishable on facts and context. In Anil Kumar Bhatia (supra), the Delhi High C…

GULAMAHEMAD HAMIDULLA KHAN,PUNE vs. ITO WARD 14(3), PUNE

In the result, Appeal filed by the assessee is partly allowed

ITA 166/PUN/2025[2014-15]Status: DisposedITAT Pune29 Aug 2025AY 2014-15

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

Section 132Section 144Section 147Section 148Section 148ASection 153CSection 250Section 69A

…आयकर अपीलीय अिधकरण ”ए” "ायपीठ पुणे म"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. /ITA No.166/PUN/2025 िनधा"रण वष" / Assessment Year: 2014-15 Gulamahemad Hamidulla Khan, V ITO, Ward 14(3), Ganesh Nagar, Phursungi, s Pune Tal. Haveli, Pune-412308, Maharashtra PAN: AMBPK7001L Appellant/ Assessee Respondent/ Revenue Assessee by Shri Pramod Shingte - (AR) Revenue by Shri Ramnath P Murkune - (DR) Date of hearing 12/08/2025 Date of pronouncement 29/08/2025 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: Thi…

SUSHEN MOHAN GUPTA,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI , DELHI

ITA 3005/DEL/2024[2017-18]Status: DisposedITAT Delhi20 May 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Date of Hearing
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).” 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot s…

SUSHEN MOHAN GUPTA ,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI , DELHI

ITA 3004/DEL/2024[2016-17]Status: DisposedITAT Delhi20 May 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).‖ 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot…

SUSHEN MOHAN GUPTA,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI , DELHI

ITA 3003/DEL/2024[2015-16]Status: DisposedITAT Delhi20 May 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).” 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot s…

SUSHEN MOHAN GUPTA ,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI, DELHI

ITA 3002/DEL/2024[2014-15]Status: DisposedITAT Delhi20 May 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).” 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot s…

SUSHEN MOHAN GUPTA,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI , DELHI

ITA 3001/DEL/2024[2013-14]Status: DisposedITAT Delhi20 May 2025AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).” 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot s…

SUSHEN MOHAN GUPTA ,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 15, DELHI , DELHI

ITA 3000/DEL/2024[2012-13]Status: DisposedITAT Delhi20 May 2025AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).” 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot s…

SUSHEN MOHAN GUPTA,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -15 , DELHI, DELHI

ITA 2999/DEL/2024[2011-12]Status: DisposedITAT Delhi20 May 2025AY 2011-12

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).‖ 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot…

A,C.I.T. CENTRAL CIR.- 2(2), NAGPUR vs. SHRI DHARAMPAL R.AGRAWAL, NAGPUR

ITA 293/NAG/2016[2008-09]Status: DisposedITAT Nagpur15 May 2025AY 2008-09

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 2(22)(e)Section 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon'ble High Court, in Para-22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Secti…

A,C.I.T. CENTRAL CIR.- 2(2), NAGPUR vs. SHRI DHARAMPAL R.AGRAWAL, NAGPUR

In the result, Revenue’s appeal being ITA no

ITA 292/NAG/2016[2007-08]Status: DisposedITAT Nagpur15 May 2025AY 2007-08

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon’ble High Court, in Para–22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Sect…

DY. C.I.T. CENTRAL CIR2(2), NAGPUR vs. M/S SHREE AGRAWAL COAL INDIA PVT. LTD.,, NAGPUR

In the result, Revenue’s appeal being ITA no

ITA 23/NAG/2016[2008-09]Status: DisposedITAT Nagpur15 May 2025AY 2008-09

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon’ble High Court, in Para–22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Sect…

DY. C.I.T. CENTRAL CIR2(2), NAGPUR vs. M/S SHREE AGRAWAL COAL INDIA PVT. LTD.,, NAGPUR

ITA 18/NAG/2016[2009-10]Status: DisposedITAT Nagpur15 May 2025AY 2009-10

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon'ble High Court, in Para-22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Secti…

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. M/S SHREE AGRAWAL FINANCE INDIA P. LTD.,, NAGPUR

ITA 172/NAG/2016[2007-08]Status: DisposedITAT Nagpur15 May 2025AY 2007-08

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 2(22)(e)Section 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon'ble High Court, in Para-22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Secti…

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. M/S SHREE AGRAWAL FINANCE INDIA P. LTD.,, NAGPUR

ITA 171/NAG/2016[2006-07]Status: DisposedITAT Nagpur15 May 2025AY 2006-07

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 2(22)(e)Section 40Section 43B

…edings before learned CIT(A)), Income Tax Appellate Tribunal, Hon'ble High Court and Hon'ble Supreme Court against such orders also not abate. Here, we wish to place reliance on the judgment of the Hon'ble Delhi High Court in CIT v/s Anil Kumar Bhatia, [2013] 352 ITR 493 (Del.), wherein the Hon'ble High Court, in Para-22, held as under:- "22. In the light of our discussion, we find it difficult to uphold the view of the Tribunal expressed in Para 9.6 of its order that since the returns of income filed by the assessee for all the six years under consideration before the search took place were processed under Secti…

SUDHIR SINGH YADAV,GURGAON vs. DCIT,CIRCLE 3(1),GURGAON, GURGAON

ITA 3001/DEL/2023[2013-14]Status: DisposedITAT Delhi07 Apr 2025AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…income for six assessment year prior to the year of search. There are no fetters or limitation under the statute, so as to curtail the jurisdiction of the AO. We derive support from the judgment of jurisdictional High court in the case of CIT Vs. Anil Bhatia 352 ITR 493 (Del).‖ 38. In the case of the assessee, there was nothing found whatsoever on the basis of which statement was taken from the three persons. These were bald statements which did not throw up any allegation of undisclosed income relating to the assessee found during the course of search. Hence, the statements taken from the three persons cannot…

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