LMJ International Ltd. v. Dy. Commissioner of Income Tax

14 DTR 540Income Tax Appellate Tribunal2008#5467 most cited

What is LMJ International Ltd. v. Dy. Commissioner of Income Tax authority for?

A notice issued under section 153A for reassessment is bad in law and any addition made in the assessment order is illegal if no incriminating document or unaccounted income was found during the course of a search in the assessee's case.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

LMJ International Ltd. · section 153A · reassessment · incriminating document · unaccounted income · search assessment · addition · bad in law · illegal assessment

Also reported as

22 SOT 31552 ITR 637

Sections most often in play

Section 115BBESection 131Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 147

Issues it is cited on

section 131(1)surrender of incomesummons under section 131paper companypermanent account numbersource of sourcesection 260section 260aadvance taxaddition under section 68search assessmentsection 234b

Judgments citing LMJ International Ltd. v. Dy. Commissioner of Income Tax

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 59/NAG/2022[2017-18]Status: DisposedITAT Nagpur25 Feb 2025AY 2017-18

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 58/NAG/2022[2015-16]Status: DisposedITAT Nagpur25 Feb 2025AY 2015-16

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 57/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Feb 2025AY 2014-15

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 56/NAG/2022[2013-14]Status: DisposedITAT Nagpur25 Feb 2025AY 2013-14

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 55/NAG/2022[2012-13]Status: DisposedITAT Nagpur25 Feb 2025AY 2012-13
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 54/NAG/2022[2011-12]Status: DisposedITAT Nagpur25 Feb 2025AY 2011-12

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

ITA 53/NAG/2022[2010-11]Status: DisposedITAT Nagpur25 Feb 2025AY 2010-11

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

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132Section 133ASection 139(1)Section 143(1)Section 143(3)Section 153ASection 234A

…Vs. Anupkumar Bhatia (2013) 352 ITR 493 (Del.) (p) CIT Vs. MGF Automobile Ltd. Delhi High Court (q) Jai Steel India Jodhpur Vs. ACIT (2013) Tax Pub. (DT) 1647 (Raj. High Court). (r) LMJ International Ltd. vs. Dy. Commissioner of Income Tax reported in (2008) 14 DTR 540 (ITAT Kolkata) (s) ACIT us. Jayendra P. Jhavery, ITA No. 2141 to 2144/Mum/2012 dated 20- 2-2014 It is therefore submitted that the notice issued u/s.153A for reassessment is bad in law and the addition made in the assessment order is illegal as no incriminating document or unaccounted income was found during the course of search in the case of ass…

DCIT CENT.CIR-8(2), MUMBAI vs. SHRI FAROOQ ALI KHAN, MUMBAI

In the result, the appeal filed by the revenue is hereby dismissed

ITA 3925/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Apr 2022AY 2014-15
For Appellant: NoneFor Respondent: Shri Achal Sharma (DR)
Section 132Section 132(4)Section 133(6)Section 143(3)Section 145Section 145(3)Section 153A

…income, r loss of a previous year, which is required to be assessed under regular assessment, the scope of which is very different from the scope of a block assessment. The Hon’ble Kolkata Tribunal has held in the case of LMJ International Ltd. v. DCIT [2008] 22 SOT 315 ( Kol. Trib.) that items of regular assessment cannot be added back in proceedings under section 153C and only undisclosed income detected in the course of search of a searched person or any other person can be added and charged to tax under section 153C of the Act. 8.28 It is pertinent to note that the GP ratios cannot be estimated by the A.O. a…

DCIT, NEW DELHI vs. M/S. VISION TOWN PLANNERS PVT. LTD., NOIDA

In the result, the appeals of the Revenue are dismissed

ITA 6068/DEL/2014[2011-12]Status: DisposedITAT Delhi24 May 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Ms. Sunita singh, CIT-DRFor Respondent: Shri Rakesh Joshi, CA
Section 143(1)Section 153ASection 153C

…as decided that addition can be made without incriminating documents in only in the case of open assessment u/s rebated assessment 153A/153C Ld. AR relied upon the decision of SSP Aviation Ltd. Vs. DCIT (2012) 346 ITR 0177 (Del), LMJ International Ltd. (2008) 22 SOT 315 Kol, MGF Automobiles Ltd. Vs. ACIT CC-7, New Delhi (ITA Nos. 4212 & 4213/Del/2011, ITAT ‘E’ Bench, New Delhi. 10 I.T.As. No.6067 & 6068/DEL/2014 Ld. AR further argued that in the amendment in Budget-2014 u/s 153C required that the paper on the basis of which satisfaction is recorded must bearing on the determination of income. “Further, we would…

DCIT, NEW DELHI vs. M/S. VISION TOWN PLANNERS PVT. LTD., NOIDA

In the result, the appeals of the Revenue are dismissed

ITA 6067/DEL/2014[2010-11]Status: DisposedITAT Delhi24 May 2021AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Ms. Sunita singh, CIT-DRFor Respondent: Shri Rakesh Joshi, CA
Section 143(1)Section 153ASection 153C

…as decided that addition can be made without incriminating documents in only in the case of open assessment u/s rebated assessment 153A/153C Ld. AR relied upon the decision of SSP Aviation Ltd. Vs. DCIT (2012) 346 ITR 0177 (Del), LMJ International Ltd. (2008) 22 SOT 315 Kol, MGF Automobiles Ltd. Vs. ACIT CC-7, New Delhi (ITA Nos. 4212 & 4213/Del/2011, ITAT ‘E’ Bench, New Delhi. 10 I.T.As. No.6067 & 6068/DEL/2014 Ld. AR further argued that in the amendment in Budget-2014 u/s 153C required that the paper on the basis of which satisfaction is recorded must bearing on the determination of income. “Further, we would…

DCIT, CC-1, , JAIPUR vs. SHRI JUGAL KISHORE GARG(DEREWALA), JAIPUR

In the result, the appeals of the Revenue are dismissed

ITA 34/JPR/2020[2014-15]Status: DisposedITAT Jaipur14 Sept 2020AY 2014-15
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri Ambrish Bedi, CIT- DR fu/kZkfjrh dh vksj ls@
Section 143(3)

…— Absence of incriminating material — Where no Assessment Year specific incriminating material or document is found, assessment of such Assessment Year cannot be disturbed by invoking the provisions of section 153C. (ii) LMJ International Ltd. Vs. DCIT (2008) 14 DTR 540 (Kol Trib) Where nothing incriminating is found in the course of search relating to any Assessment Year, the assessment of such years cannot be disturbed. Items of regular assessment cannot be added back in the proceeding u/s 153C when no incriminating documents were found in respect of the disallowed amount in the search proceedings. (ii) ACTT Vs…

M/S. KALYAN AWAS VIKAS PVT. LTD, D-25, LAL BAHADUR NAGAR, JAWAHAR LAL NEHRU MARG, JAIPUR,JAIPUR vs. ACIT, CENTRAL CIRCLE-1, JAIPUR, CENTRAL CIRCLE-1, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 329/JPR/2019[2014-15]Status: DisposedITAT Jaipur11 Sept 2020AY 2014-15
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri B.K.. Gupta , CIT DR
Section 143(3)Section 153A

…was placed on the following judicial pronouncements: (i) Anil Kumar Bhatia Vs. Assistant Commissioner of Income Tax (2010) 1 ITR (Trib) 484 (Del) (ii) Singhad Technical Education Society Vs. ACIT (2011) 57 DTR 241 (iii) LMJ International Ltd. Vs. DCIT (2008) 14 DTR 540 (Kol Trib) (iv) ACIT Vs. Gambhir Silk Mills (2010) 6 ITR 376 (Ahm. Trib) 5. With regard to merit of disallowance, it was contended by the ld AR that the interest expenditure was incurred wholly and exclusively for the purpose of business and for the commercial expediency in so far as advances were given to the sister concerns, whose project was un…

M/S. KALYAN AWAS VIKAS PVT. LTD. D-25, LAL BAHADUR NAGAR, JAWAHAR LAL NEHRU MARG, JAIPUR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR, CENTRAL CIRCLE-1, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 328/JPR/2019[2013-14]Status: DisposedITAT Jaipur11 Sept 2020AY 2013-14
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri B.K.. Gupta , CIT DR
Section 143(3)Section 153A

…was placed on the following judicial pronouncements: (i) Anil Kumar Bhatia Vs. Assistant Commissioner of Income Tax (2010) 1 ITR (Trib) 484 (Del) (ii) Singhad Technical Education Society Vs. ACIT (2011) 57 DTR 241 (iii) LMJ International Ltd. Vs. DCIT (2008) 14 DTR 540 (Kol Trib) (iv) ACIT Vs. Gambhir Silk Mills (2010) 6 ITR 376 (Ahm. Trib) 5. With regard to merit of disallowance, it was contended by the ld AR that the interest expenditure was incurred wholly and exclusively for the purpose of business and for the commercial expediency in so far as advances were given to the sister concerns, whose project was un…

M/S. KALYAN AWAS VIKAS PVT. LTD. ,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, all these three appeals of the assessee are allowed

ITA 327/JPR/2019[2012-13]Status: DisposedITAT Jaipur11 Sept 2020AY 2012-13
For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri B.K.. Gupta , CIT DR
Section 143(3)Section 153A

…was placed on the following judicial pronouncements: (i) Anil Kumar Bhatia Vs. Assistant Commissioner of Income Tax (2010) 1 ITR (Trib) 484 (Del) (ii) Singhad Technical Education Society Vs. ACIT (2011) 57 DTR 241 (iii) LMJ International Ltd. Vs. DCIT (2008) 14 DTR 540 (Kol Trib) (iv) ACIT Vs. Gambhir Silk Mills (2010) 6 ITR 376 (Ahm. Trib) 5. With regard to merit of disallowance, it was contended by the ld AR that the interest expenditure was incurred wholly and exclusively for the purpose of business and for the commercial expediency in so far as advances were given to the sister concerns, whose project was un…

ASST CIT CEN CIR 39, MUMBAI vs. SURESH JANARDAN RAUT, RAIGAD

In the result, the appeal by the Revenue is dismissed and the appeal by the

ITA 6630/MUM/2013[2006-07]Status: DisposedITAT Mumbai18 Sept 2018AY 2006-07

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm

For Appellant: Shri Prakash PanditFor Respondent: Shri R. Manjunatha Swamy
Section 153ASection 153C

…ed, the Assessing Officer can reopen the assessment or reassessment already made without following the provisions of s. 147, 148 and 151 of the Act and determine the total income of the assessee. Reliance is placed on:- LMJ International Ltd., vs. DC1T (2008) 22 SOT 315 All Cargo Global Logistics Ltd. Vs. ACIT 137 ITD 0287 For the said reason, the grounds 2 and 3 are held in favour of the assessee. 6. Against the above order, the Revenue is in appeal before us. 5 M/s. Suresh Janardan Raut 7. We have heard both the counsel and perused the records. The ld. ld. Departmental Representative relied upon the orders…

ASSISTANT COMMISSIONER OF INCOME-TAX,CIRCLE-2,(1), BILASPUR(CG) vs. SHRI PRAVEEN SALUJA, BILASPUR(CG)

In the result, appeal filed by Revenue is dismissed

ITA 92/BIL/2011[2007-08]Status: DisposedITAT Raipur17 Jan 2018AY 2007-08
For Appellant: Shri R.B.Doshi, ARFor Respondent: Shri R.K.Singh, CITDR
Section 106Section 131Section 69ASection 69C

…unsustainable. In support, the assessee relied on the decisions in Narain Singh Bhati v. ACIT 40 TTJ 381; Rohitas Yadaw v. ITO 114 TTJ 973; ACIT v. H M Satyanarayana Setty 71 TTJ 186; ITO v. Rajendra Kumar Taparia 106 TTJ 712 and LMJ International Ltd v. DCIT 22 SOT 315. 24. The CIT(A) after considering the submissions of the assessee deleted the addition of Rs.1,91,133/- for the assessment year 2006-07 and Rs.2,12,566/- for the assessment year 2007-08 after observing as under :- “5.3 I have carefully considered the submissions made on behalf of the appellant with reference to the facts obtaining from the record.…

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

ITA 132/BIL/2011[2007-08]Status: DisposedITAT Raipur10 Jan 2018AY 2007-08

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…alf-baked discussion of facts or un- corroborated piece of evidence. If nothing incriminating was found during search or thereafter in relation thereto, no addition should be made in respect of such issues, as held in [LMJ International Ltd. v. Dy. CIT (2008) 22 SOT 315 (Kol.)]; Senairam Doongarmal Agency (P.) Ltd. v. K.E. Johnson (1964) 52 ITR 637 (Assam) (FB) and N.K. Textile Mills v. CIT (1996) 62 ITR 58 (Punj.). 1.36 Courts have uniformly taken the view that post-search assessment should be with reference to the seized assets and material gathered during search. It may include the result of further inquiry bu…

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

ITA 131/BIL/2011[2006-07]Status: DisposedITAT Raipur10 Jan 2018AY 2006-07

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…alf-baked discussion of facts or un- corroborated piece of evidence. If nothing incriminating was found during search or thereafter in relation thereto, no addition should be made in respect of such issues, as held in [LMJ International Ltd. v. Dy. CIT (2008) 22 SOT 315 (Kol.)]; Senairam Doongarmal Agency (P.) Ltd. v. K.E. Johnson (1964) 52 ITR 637 (Assam) (FB) and N.K. Textile Mills v. CIT (1996) 62 ITR 58 (Punj.). 1.36 Courts have uniformly taken the view that post-search assessment should be with reference to the seized assets and material gathered during search. It may include the result of further inquiry bu…

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

ITA 130/BIL/2011[2005-06]Status: DisposedITAT Raipur10 Jan 2018AY 2005-06

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…alf-baked discussion of facts or un- corroborated piece of evidence. If nothing incriminating was found during search or thereafter in relation thereto, no addition should be made in respect of such issues, as held in [LMJ International Ltd. v. Dy. CIT (2008) 22 SOT 315 (Kol.)]; Senairam Doongarmal Agency (P.) Ltd. v. K.E. Johnson (1964) 52 ITR 637 (Assam) (FB) and N.K. Textile Mills v. CIT (1996) 62 ITR 58 (Punj.). 1.36 Courts have uniformly taken the view that post-search assessment should be with reference to the seized assets and material gathered during search. It may include the result of further inquiry bu…

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

ITA 128/BIL/2011[2003-04]Status: DisposedITAT Raipur10 Jan 2018AY 2003-04

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…alf-baked discussion of facts or un- corroborated piece of evidence. If nothing incriminating was found during search or thereafter in relation thereto, no addition should be made in respect of such issues, as held in [LMJ International Ltd. v. Dy. CIT (2008) 22 SOT 315 (Kol.)]; Senairam Doongarmal Agency (P.) Ltd. v. K.E. Johnson (1964) 52 ITR 637 (Assam) (FB) and N.K. Textile Mills v. CIT (1996) 62 ITR 58 (Punj.). 1.36 Courts have uniformly taken the view that post-search assessment should be with reference to the seized assets and material gathered during search. It may include the result of further inquiry bu…

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