Bench: Honourable The Chief Justice Honourable Mrs. Justice Susmita Phukan Khaund Judgment Date : 02-08-2023 (S.P. Khaund, J) 1. Heard Mr. S. Chetia, Learned Senior Standing Counsel, Income Tax Department & Mr. G.N. Sahewalla, Learned Senior Counsel For The Respondent Assisted By Learned Counsel Mr. M. Sahewalla. 2. This Is An Appeal U/S 260A Of Income Tax Act, 1961 (The I.T. Act For Short) Against The Order Dated 14.11.2018 Passed By The Income Tax Appellate Tribunal ‘E’ Court

disallowances of Rs. 15,46,46,174/- u/s 40(a)(ia) of the I.T. Act, by holding that processing u/s 143(I) is an assessment which is concluded and unabated which cannot be disturbed in the absence of incriminating material found in the course of search. (ii) Whether the Hon’ble ITAT was justified in holding that the inference drawn