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

14. The Legislature does not differentiate whether the assessments originally were framed u/s 143(1) or 143(3) or 147 of the Act. Hence unless there is any incriminating material found during the course of such concluded year, the statute does not confer any power on the learned AO to disturb the findings even thereon and the income determined thereon