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

12 was originally completed u/s 143(1) of the Act and the time limit for issuance of notice u/s Page No.# 7/10 143(2) of the Act had expired and hence it falls under concluded proceedings as on the date of search. 14. The Legislature does not differentiate whether the assessments originally were framed u/s