In the result, both the appeals filed by the Revenue for AY
Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad
reassessment was pending on the date of initiation of search under section 132 or making of requisition under section 132A, while computing the total income of the assessee under section 153A of the Act, additions or disallowances can be made only on the basis of the incriminating material found during the search or requisition. In the present case