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“search assessment”

Search & SeizureSection 153ASection 153A2,574 judgments

The decision most relied on for search assessment is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on search assessment

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.
374 ITR 645 · 2015 · High Court
1,823
citing judgments

In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

Pr. CIT v. Meeta Gutgutia
395 ITR 526 · 2017 · High Court
1,226
citing judgments

In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.

All Cargo Global Logistics Ltd. v. DCIT
137 ITD 287 · 2012 · ITAT
907
citing judgments

In non-abated assessments, the Assessing Officer can make additions under section 153A based on books of accounts or documents found during a search but not produced during the original assessment, provided such material is incriminating.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Judgments citing search assessment

Mewar Hospital Pvt. Ltd., Udaipur vs. ACIT, Central Circle-2, Udaipur

In the result the appeal of the assessee in ITA No

ITA 141/JODH/2022[2015-16]Status: DisposedITAT Jodhpur12 Oct 2023AY 2015-16
Section 143(3)Section 145Section 153A

Since, the issue involved in all these appeals are related to the one assessee and the facts are almost similar related to the search assessment. Therefore, with the consent of both the parties the matter were heard together and are disposed with this common order. 2.1 The grounds of appeal ... incriminating material, the revenue has merely stated that the assessee has paid the cash to doctors and no TDS is made. In the search assessment no such addition can be made as held in the case of Principal Commissioner of Income Tax, Central-3 Vs. Abhisar Buildwell P. Ltd(Supra

Mewar Hospital Pvt. Ltd., Udaipur vs. ACIT, Central Circle-2, Udaipur

In the result the appeal of the assessee in ITA No

ITA 140/JODH/2022[2014-15]Status: DisposedITAT Jodhpur12 Oct 2023AY 2014-15
Section 143(3)Section 145Section 153A

Since, the issue involved in all these appeals are related to the one assessee and the facts are almost similar related to the search assessment. Therefore, with the consent of both the parties the matter were heard together and are disposed with this common order. 2.1 The grounds of appeal ... incriminating material, the revenue has merely stated that the assessee has paid the cash to doctors and no TDS is made. In the search assessment no such addition can be made as held in the case of Principal Commissioner of Income Tax, Central-3 Vs. Abhisar Buildwell P. Ltd(Supra

Mewar Hospital Pvt. Ltd., Udaipur vs. ACIT, Central Circle-2, Udaipur

In the result the appeal of the assessee in ITA No

ITA 139/JODH/2022[2012-13]Status: DisposedITAT Jodhpur12 Oct 2023AY 2012-13
Section 143(3)Section 145Section 153A

Since, the issue involved in all these appeals are related to the one assessee and the facts are almost similar related to the search assessment. Therefore, with the consent of both the parties the matter were heard together and are disposed with this common order. 2.1 The grounds of appeal ... incriminating material, the revenue has merely stated that the assessee has paid the cash to doctors and no TDS is made. In the search assessment no such addition can be made as held in the case of Principal Commissioner of Income Tax, Central-3 Vs. Abhisar Buildwell P. Ltd(Supra

M/S. Pragati Milk Product Pvt. Ltd., Cuttack vs. ACIT, Central Circle, Cuttack

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

ITA 145/CTK/2022[2013-14]Status: DisposedITAT Cuttack11 Oct 2023AY 2013-14

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri Dr. Abani Kanta Nayak, CIT-DR
Section 143(3)Section 153ASection 154Section 80I

cases are identical. It was the submission that there was search in the premises of the assessee. As a consequence of search, assessment came to be completed u/s.153A of the Act. In the assessment u/s.153A of the Act, the assessee had been granted the benefit of deduction u/s.80IB ... clearly shows that in the original assessment order for the assessment year 2014-2015, the AO himself in scrutiny proceedings and that too a search assessment scrutiny proceedings, considered the claim of deduction/s.80IB(11A) of the Act and then came to the conclusion that initial year is the assessment year

M/S. Pragati Milk Product Pvt. Ltd., Cuttack vs. ACIT, Central Circle, Cuttack

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

ITA 144/CTK/2022[2014-15]Status: DisposedITAT Cuttack11 Oct 2023AY 2014-15

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri Dr. Abani Kanta Nayak, CIT-DR
Section 143(3)Section 153ASection 154Section 80I

cases are identical. It was the submission that there was search in the premises of the assessee. As a consequence of search, assessment came to be completed u/s.153A of the Act. In the assessment u/s.153A of the Act, the assessee had been granted the benefit of deduction u/s.80IB ... clearly shows that in the original assessment order for the assessment year 2014-2015, the AO himself in scrutiny proceedings and that too a search assessment scrutiny proceedings, considered the claim of deduction/s.80IB(11A) of the Act and then came to the conclusion that initial year is the assessment year

M/S. Pragati Milk Product Pvt. Ltd., Cuttack vs. ACIT, Central Circle, Cuttack

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

ITA 143/CTK/2022[2012-13]Status: DisposedITAT Cuttack11 Oct 2023AY 2012-13

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri Dr. Abani Kanta Nayak, CIT-DR
Section 143(3)Section 153ASection 154Section 80I

cases are identical. It was the submission that there was search in the premises of the assessee. As a consequence of search, assessment came to be completed u/s.153A of the Act. In the assessment u/s.153A of the Act, the assessee had been granted the benefit of deduction u/s.80IB ... clearly shows that in the original assessment order for the assessment year 2014-2015, the AO himself in scrutiny proceedings and that too a search assessment scrutiny proceedings, considered the claim of deduction/s.80IB(11A) of the Act and then came to the conclusion that initial year is the assessment year

Sushil Singla, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, the appeals of the assessee are allowed

ITA 1559/DEL/2023[2016-17]Status: DisposedITAT Delhi10 Oct 2023AY 2016-17

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri N. G. Joseph Gangte, CIT DR
Section 132Section 143(1)Section 143(2)Section 153A

during the course of search qua the addition made towards cash deposits in the bank account. We find that the ld AO in the search assessment u/s 143(1) of the Act for the aforesaid years had merely examined the bank account maintained by the assessee with

Sushil Singla, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, the appeals of the assessee are allowed

ITA 1558/DEL/2023[2015-16]Status: DisposedITAT Delhi10 Oct 2023AY 2015-16

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri N. G. Joseph Gangte, CIT DR
Section 132Section 143(1)Section 143(2)Section 153A

during the course of search qua the addition made towards cash deposits in the bank account. We find that the ld AO in the search assessment u/s 143(1) of the Act for the aforesaid years had merely examined the bank account maintained by the assessee with

Sushil Singla, Faridabad vs. DCIT Central Circle-II, Faridabad

In the result, the appeals of the assessee are allowed

ITA 1557/DEL/2023[2014-15]Status: DisposedITAT Delhi10 Oct 2023AY 2014-15

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri N. G. Joseph Gangte, CIT DR
Section 132Section 143(1)Section 143(2)Section 153A

during the course of search qua the addition made towards cash deposits in the bank account. We find that the ld AO in the search assessment u/s 143(1) of the Act for the aforesaid years had merely examined the bank account maintained by the assessee with

DCIT, Central Circle-II, Noida vs. M G Metalloy Pvt. Ltd., Noida

In the result, the appeals filed by the Revenue are dismissed and the cross objections filed by the assessee are allowed

ITA 4462/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Oct 2023AY 2010-11

Bench: SHRI SHAMIM YAHYA (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri Pranav Yadav, AdvocateFor Respondent: Shri Subhra Jyoti Chakraborty, CIT DR
Section 132(1)Section 153ASection 153CSection 153DSection 68

placed 12 ITA Nos.4461 & 4462/Del./2019 CO Nos.129 & 130/Del./2019 before the approving authority i.e. Joint / Addl. Commissioner (designated authority giving approval to search assessment under Section 153D of the Act) for his perusal and prior approval. The approving authority is necessarily required to objectively evaluate such draft assessment order ... infallible impression of approval on dotted line and without discharging the onus placed on competent authority thus defeats the intrinsic purpose of supervision of search assessments. Such hawkish approval has thus tarred the assessment and rendered it bad in law. 11. It may be pertinent to observe, Section 153D bestows

DCIT, Central Circle-II, Noida vs. M G Metalloys P.Ltd, Noida

In the result, the appeals filed by the Revenue are dismissed and the cross objections filed by the assessee are allowed

ITA 4461/DEL/2019[2009-10]Status: DisposedITAT Delhi10 Oct 2023AY 2009-10

Bench: SHRI SHAMIM YAHYA (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri Pranav Yadav, AdvocateFor Respondent: Shri Subhra Jyoti Chakraborty, CIT DR
Section 132(1)Section 153ASection 153CSection 153DSection 68

placed 12 ITA Nos.4461 & 4462/Del./2019 CO Nos.129 & 130/Del./2019 before the approving authority i.e. Joint / Addl. Commissioner (designated authority giving approval to search assessment under Section 153D of the Act) for his perusal and prior approval. The approving authority is necessarily required to objectively evaluate such draft assessment order ... infallible impression of approval on dotted line and without discharging the onus placed on competent authority thus defeats the intrinsic purpose of supervision of search assessments. Such hawkish approval has thus tarred the assessment and rendered it bad in law. 11. It may be pertinent to observe, Section 153D bestows

V D Devasia, Kottayam vs. ACIT, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 50/COCH/2022[2014-2015]Status: DisposedITAT Cochin29 Sept 2023AY 2014-2015

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

V D Devasia, Kottayam vs. ACIT, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 49/COCH/2022[2013-2014]Status: DisposedITAT Cochin29 Sept 2023AY 2013-2014

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

V D Devasia, Kottayam vs. ACIT, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 48/COCH/2022[2012-2013]Status: DisposedITAT Cochin29 Sept 2023AY 2012-2013

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

Chengazhasseril Thomas Kurian, Kottayam vs. ACIT Central Circle Kottayam, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 474/COCH/2022[2014-2015]Status: DisposedITAT Cochin29 Sept 2023AY 2014-2015

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

Chengazhasseril Thomas Kurian, Kottayam vs. ACIT Central Circle Kottayam, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 473/COCH/2022[ 2012-2013]Status: DisposedITAT Cochin29 Sept 2023

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

Chengazhasseril Thomas Kurian, Kottayam vs. ACIT Central Circle Kottayam, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 472/COCH/2022[2011-2012]Status: DisposedITAT Cochin29 Sept 2023AY 2011-2012

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

V D Devasia, Kottayam vs. ACIT, Kottayam

In the result, the appeals by the assessees are partly allowed and partly allowed for statistical purposes

ITA 47/COCH/2022[2011-2012]Status: DisposedITAT Cochin29 Sept 2023AY 2011-2012

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

For Appellant: Shri Joseph Markose, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 132Section 132(4)Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 64

payment of document prices as well as on money payment. c. The assessee was stated to be involved in a business activity before the search assessment. To avoid the rigour of explaining huge credits in the bank invented the theory of commission and non-maintenance of books of account

J M Mhatre Infra Pvt Ltd., Panvel vs. ACIT, CC-1, Thane

In the result, appeal of the assessee is partly allowed

ITA 1670/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 Sept 2023AY 2017-18
Section 132Section 143(3)Section 153A

dated 31/03/2023 for the quantum of assessment passed u/s.153A r.w.s. 143(3). 2. In the sets of two appeals, which are pertaining to pre-search assessments passed u/s.143(3) for A.Y. 2013-14 and 2014-15, wherein the common issue involved pertains to estimation of income from direct contract receipts ... Rs.5,50,000/- as claimed by the assessee under Chapter VIA in A.Y.2013-14. 3. We will take up the appeal pertaining to pre-search assessments passed u/s.143(3) for the A.Y.2013-14 and our finding given therein will apply mutatis mutandis in the appeal for A.Y. 2014-15, because the finding

J M Mhatre Infra Pvt Ltd., Panvel vs. ACIT, CC-1, Thane

In the result, appeal of the assessee is partly allowed

ITA 1669/MUM/2023[2016-17]Status: DisposedITAT Mumbai22 Sept 2023AY 2016-17
Section 132Section 143(3)Section 153A

dated 31/03/2023 for the quantum of assessment passed u/s.153A r.w.s. 143(3). 2. In the sets of two appeals, which are pertaining to pre-search assessments passed u/s.143(3) for A.Y. 2013-14 and 2014-15, wherein the common issue involved pertains to estimation of income from direct contract receipts ... Rs.5,50,000/- as claimed by the assessee under Chapter VIA in A.Y.2013-14. 3. We will take up the appeal pertaining to pre-search assessments passed u/s.143(3) for the A.Y.2013-14 and our finding given therein will apply mutatis mutandis in the appeal for A.Y. 2014-15, because the finding