DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL BAMALWA, DIBRUGARH
In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed
ITA 51/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13
Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar
b) Whether the Tribunal is right in law in holding that the addition should be based on the incriminating material found during the course of search under new procedure of assessment u/s 153A which is different from earlier procedure u/s 158BC r.w.s. 158BB of the Act and by reading into the section, the words 'the incriminating material found during