Appeal are dismissed
Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble
reassess the total income of six years immediately preceding the assessment year relevant to the previous year in which search is conducted. Applying this yardstick, the six years would go up to 2013-14. The search assessment year, namely, 2019-20 has to be excluded. This is because, the statute talks of the six years preceding the search assessment year