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“undisclosed income”

Search & SeizureSection 153ASection 153A9,092 judgments

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

Leading authorities on undisclosed income

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.

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

CIT v. P. Mohanakala
291 ITR 278 · 2007 · Supreme Court
525
citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
citing judgments

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

CIT v. Gurinder Singh Bawa
386 ITR 483 · 2016 · High Court
416
citing judgments

If no incriminating material is found during a search operation regarding a particular issue, then no addition can be made concerning that issue in an assessment under section 153A of the Income-tax Act.

Judgments citing undisclosed income

Chandra Mohan Badaya, Jaipur vs. DCIT, Central Circle, Ajipur

In the result, the appeal of the assessee is allowed

ITA 1054/JPR/2024[2013-2014]Status: DisposedITAT Jaipur12 Feb 2025AY 2013-2014

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. L. Gupta, CAFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 132Section 139(1)Section 143(3)Section 153A

coloring device to dupe the Department. Hence, the investment to the extent to Rs. 431000/- has been made by the assessee from his undisclosed income on the date of registration of sale deed i.e. 30-07-2012 and same is undisclosed investment of the assessee

Dr. Raj Mehrotra, Lucknow vs. Asst. Commissioner of Income Tax, Lucknow

ITA 1371/LKW/1997[Block]Status: HeardITAT Lucknow12 Feb 2025

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 132Section 158BSection 260A

aforesaid assessment order, the assessee’s total income was assessed at Rs.8,18,965/- including an amount of Rs.1,69,280/- as undisclosed income. The assessee filed appeal against the aforesaid assessment order in Income Tax Appellate Tribunal (“ITAT”, for short) . Vide earlier order dated 18/09/2014, Coordinate Bench of ITAT

ACIT CC -6(1), Mumbai, Bkc vs. Prashant Prakash Nilawar, Pnue

In the result, appeal of the assessee is partly allowed

ITA 5689/MUM/2024[2021-22]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

draw an adverse inference against the assessee, unless those WhatsApp messages are supported by corroborative evidences to indicate that those messages and contents represents undisclosed income of the assessee. ……The AO neither bring on record from which person, the assessee has received cash and to whom the assessee has distributed

Prashant Prakash Nilawar, Pune vs. DCIT CC 6(1)-Mumbai, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5073/MUM/2024[2021-2022]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-2022

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

draw an adverse inference against the assessee, unless those WhatsApp messages are supported by corroborative evidences to indicate that those messages and contents represents undisclosed income of the assessee. ……The AO neither bring on record from which person, the assessee has received cash and to whom the assessee has distributed

Blackstone Infracon Pvt. Ltd, New Delhi vs. ITO Ward-5(1), New Delhi

In the result, appeal filed by the assessee are partly allowed

ITA 2735/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Feb 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

having been established. 8. On the other hand, Ld DR objected to the same and submitted that AO was convinced that there is undisclosed income. Therefore, there is proper satisfaction. With regard to approval granted u/s 153D, she submitted that the approval was granted after a day and only

Sarthak Ispat Pvt. Ltd., Raipur vs. Income Tax Officer-2(1), Raipur

ITA 431/RPR/2024[2012-13]Status: DisposedITAT Raipur11 Feb 2025AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 431/Rpr/2024 ("नधा"रण वष" Assessment Year: 2012-13) Sarthak Ispat Pvt. Ltd., V Income Tax Officer-2(1), Raipur S Udaya Society, Vivekanand Ashram, Raipur, 492001, C.G. Pan: Aalcs5029H (अपीलाथ"/Appellant) . (""थ" / Respondent) . िनधा"रती की ओर से /Assessee By : Shri Subhash Agrawal, Adv. राज" की ओर से /Revenue By : Shri S. L. Anuragi, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 29.01.2025 घोषणा की तारीख/Date Of Pronouncement : 11.02.2025

For Appellant: Shri Subhash Agrawal, AdvFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68

accordingly, statutory notices u/s 148 and section 142(1) are issued. After deliberations, the assessment was completed with certain additions, (i) on account of undisclosed income received by the assessee in the guise of share capital and share premium for Rs.3,25,00,000/-; (ii) Due to discrepancies found during ... other words, there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income would be brought to tax". (Emphasis supplied by us) iv. Although Section 153 A does not say that additions should be strictly made

Jagdish Kumar Arora, Bhawanimandi vs. DCIT, Central Circle- Kota, Kota

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

source of these assets" and in the event of failure to prove these, " the revenue could legitimately hold that these assets represented the undisclosed income of the assessee". Roshan Di Hatti (supra) is case on the similar issue involving issue of stock in trade which was included by the assessee ... source of these assets and in the event of failure to prove these, the revenue could legitimately hold that these assets represented the undisclosed income of the assessee. There is no presumption in favor of business income. Onus to prove is on assessee. The Hon'ble Supreme Court

P. Maneklal and Co., Vadodara vs. The Dy.CIT, Central Circle-1, Vadodara

In the result, the appeal of the Assessee is allowed

ITA 1864/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad11 Feb 2025AY 2019-20

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri V.K. Mangla, Sr DR
Section 115BSection 131Section 250Section 69ASection 69C

assessee, in his statement, had admitted that the excess stock valued at Rs. 4,78,500/- would be declared as undisclosed income for the AY 2019-20 and offered for taxation in addition to the regular income. However, the assessee had failed to include the surrendered amount ... relevant assessment year. Therefore, the Assessing Officer made addition of Rs.4,78,500/- to the return of income of the assessee as undisclosed income u/s 69A of the Act. Before the Ld. CIT(A) the assessee reiterated the submissions made before the Assessing Officer, asserting that the discrepancy in stock

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 57/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

explain as to how it does not constitute income and much less my income. (ii) The basis for assessing an amount as undisclosed income cannot be on presumption much less the wealth tax assessment as mentioned in the letter of the assessing officer. In this connection it is further submitted ... explain as to how it does not constitute income and much less my income. (ii) The basis for assessing an amount as undisclosed Income cannot be on presumption much less the wealth tax assessment as mentioned in the letter of the assessing officer. In this connection it is further submitted

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 55/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

explain as to how it does not constitute income and much less my income. (ii) The basis for assessing an amount as undisclosed income cannot be on presumption much less the wealth tax assessment as mentioned in the letter of the assessing officer. In this connection it is further submitted ... explain as to how it does not constitute income and much less my income. (ii) The basis for assessing an amount as undisclosed Income cannot be on presumption much less the wealth tax assessment as mentioned in the letter of the assessing officer. In this connection it is further submitted

Raghuvir Retailers Pvt. Ltd., Kolkata vs. PCIT-2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 919/KOL/2024[2013-14]Status: DisposedITAT Kolkata11 Feb 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Pcit-2 Raghuvir Retailers Pvt. Ltd. Aaykar Bhavan P-7, Mandawa Shikhar, 151, Sarat Chowringhee Square, Kolkata- Bose Road, Kolkata-700026, Vs. 700069, West Bengal West Bengal (Respondent) (Appellant) Pan No. Aaecr8231M Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 19.12.2024 Date Of Pronouncement : 11.02.2024

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Subhendu Datta, DR
Section 147Section 148Section 263Section 69A

right as to the finality of proceedings. Queitus of the completed assessment can be disturbed only when there is information or evidence regarding undisclosed income or AO had information in his possession showing escapement of income. So when an AO receives an information regarding undisclosed income of an assessee

Deputy Commissioner of Income Tax, Kolkata vs. Dollar Holding Pvt. Ltd., Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 1729/KOL/2024[2017-18]Status: DisposedITAT Kolkata11 Feb 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan, ARFor Respondent: Shri Abhijit Kundu, DR
Section 14ASection 68Section 69C

where assessing officer solely based on statement of assessee’s director recorded during search operation treated share application money received by assessee company as undisclosed income and made additions u/s 68 of the Act, since said statement was retracted and there was no cash trail or any other corroborative evidence ... during the course of search, made a categorical admission under section 132(4) that the cash amount seized belonged to him and it represented undisclosed income not recorded in the books of accounts. The assessee did not immediately retract from the above admission but only during the assessment proceedings

Deputy Commissoenr of Income Tax, Kolkata vs. Dollar Holding Pvt. Ltd., Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 1728/KOL/2024[2015-16]Status: DisposedITAT Kolkata11 Feb 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan, ARFor Respondent: Shri Abhijit Kundu, DR
Section 14ASection 68Section 69C

where assessing officer solely based on statement of assessee’s director recorded during search operation treated share application money received by assessee company as undisclosed income and made additions u/s 68 of the Act, since said statement was retracted and there was no cash trail or any other corroborative evidence ... during the course of search, made a categorical admission under section 132(4) that the cash amount seized belonged to him and it represented undisclosed income not recorded in the books of accounts. The assessee did not immediately retract from the above admission but only during the assessment proceedings

Surendra Kumar Mishra, Allahabad vs. ACIT, Cir-2, Allahabad

In the result, the appeal of the assessee is dismissed

ITA 140/ALLD/2023[2002-03]Status: DisposedITAT Allahabad10 Feb 2025AY 2002-03

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2002-03 Surendra Kumar Mishra, Vs. Assistant Commissioner Of 794A/1, Sohabatiyabagh, Income Tax, Circle-2, Allahabad Allahabad-211006, U.P. Pan:Aibpm4858R (Appellant) (Respondent) Assessee By: Sh. Ashish Bansal, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 10.02.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Under Section 250 R.W.S. 254 Of The Income Tax Act, 1961 On 26.10.2023. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because The Cit(A) Has Erred In Law As Well As On Facts In Dismissing The 'Additional Ground' Relating To Non-Issuance Of Notice Under Section 143(2) Of The Act, Raised Before The Appellate Authority During The Course Of First Round Of Litigation, Which Has Been Remanded Back By The Hon'Ble Itat In Terms Of Order Dated 09.11.2012, By Observing That The Return Filed By The Appellant In Terms Of Letter Dated 10.11.2008 As Not A Valid Return In Compliance To Notice Dated 11.02.2008 Issued Under Section 148 Of The Act, As The Said Letter Was Filed By The Appellant After The Time Limit Of 30 Days Provided To Do So In Terms Of Notice Dated 11.02.208 Issued Under Section 148 Of The Act. 2. Because The Cit(A) Has Erred In Law As Well As On Facts In Observing That The Appellant Could Not Have Demand For Issuance Of Notice Under Section 143(2) Of The 1 Surendra Kumar Mishra

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. A.K. Singh, Sr. DR
Section 142(1)Section 143(2)Section 148Section 250Section 69C

stood fully explained and the "Authorities" below have erred in law and on facts in holding the same to be representing the "undisclosed income" of the appellant and in subjecting the same to assessment in his hand, by evoking the provisions of section 69C of the Act. 10. BECAUSE ... hold charges’ stood fully explained by the confirmation of Shri. Rajat Kamal Mitra and therefore, the same should not have been held to be undisclosed income in the hands of the assessee. Reliance was placed on the case of CIT vs. Smt. P.K. Noor Jahan

Deputy Commissioner O F Income Tax, Raipur vs. Balajee Loha Pvt. Ltd., Raipur

ITA 356/RPR/2024[2014-15]Status: DisposedITAT Raipur10 Feb 2025AY 2014-15

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 356/Rpr/2024 (िनधा"रण वष" Assessment Year: 2014-15)

For Appellant: Shri Amit M. Jain, Advocate &For Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 68

proving the identity, creditworthiness and genuineness of the share applicants··and hence the share application money credited in its books is treated as undisclosed income charged to tax u/s 68 of the Act. 3.5 In the light of the above discussion, I find no merits in the arguments ... share application money credited in its books of account for the relevant assessment year in question and hence the same is treated as undisclosed income of the assessee u/s 68 of the Act. It has been elaborately established in the preceding par that the assessee had failed to discharge

Subramaniam Swaminathan Iyer, Bhilai, Durg vs. Deputy Commissioner of Income Tax-1(1), Bhilai, Durg

In the result, appeal of the assessee is partly allowed/partly allowed for statistical purposes in terms of our aforesaid observations

ITA 71/RPR/2023[2012-13]Status: DisposedITAT Raipur10 Feb 2025AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.71/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Subramaniam Swaminathan Iyer 12-A/7, Nehru Nagar, Bhilai (C.G.)-490 020 Pan: Anwps2381P

For Appellant: S/shri Milind Bhusari, AdvocateFor Respondent: Shri S.L Anuragi, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 2(22)(e)Section 68

credit balance are also not correct. This establishes the fact that the appellant has made unexplained investment in acquisition of corresponding assets from his undisclosed income. The AO treated the amount of unexplained credit of Rs.2,00,00,000/- as unexplained cash credit under section ... balance of the creditors/associate credit balances were projected which, thus, had sourced the investment in the acquisition of corresponding assets by him from his undisclosed income, we are afraid will have no bearing on the adjudication of the issue in hand for the year under consideration

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

before making the addition under Section 68, to prove that the share application monies actually emanated from the assessee and represented undisclosed income of the assessee. He, however, did not cite any of those decisions. In any case the law having been laid down by the Supreme Court

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

before making the addition under Section 68, to prove that the share application monies actually emanated from the assessee and represented undisclosed income of the assessee. He, however, did not cite any of those decisions. In any case the law having been laid down by the Supreme Court

Assistant Commissioner of Income Tax, Circle-5, Nagpur vs. Shri Mukesh Champalal Malviya, Nagpur

In the result, assessee’s appeal is allowed for statistical purposes

ITA 389/NAG/2019[2011-12]Status: DisposedITAT Nagpur10 Feb 2025AY 2011-12

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

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147

substantial additions are made on account of unexplained credits 2 Shri Mukesh Champalal Malviya ITA no.389/Nag./2019 received from parties and 10% of undisclosed income on those unexplained credits. 3. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT (Appeal) is right ... directions of the learned JCIT, Nagpur, the credits in the aforesaid bank account amounting to = 3,51,00,000, which has been considered as undisclosed income of the assessee from undisclosed sources, as discussed in detail by the Assessing Officer in its assessment order vide Para

Asstt. Commissioner of Incomet Ax Central Circle-1(1), Nagpur vs. Shri Sanjay Gaurishankar Agrawal, Nagpur

In the result, appeal by the Revenue stands dismissed

ITA 62/NAG/2018[2013-2014]Status: DisposedITAT Nagpur10 Feb 2025AY 2013-2014

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

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 132Section 139Section 143(1)Section 143(2)Section 143(3)Section 153ASection 68

assessment under section 153A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment