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

disallowance u/s 40(a)(ia) of the Act for the Assessment Year 2011-12 were not dealt with. 13. It was held by the Tribunal that the scheme of act provides for abatement of pending proceedings as on date of search. It is not in dispute that the assessment for the year 2011- 12 was originally completed u/s 143(1