Section 153A search assessments need incriminating material for completed cases; absent it, reassessment is limited.

Section 153A search assessments are confined, for completed or unabated assessments, by the existence of incriminating material found during the search or requisition. Where no such material is found, completed assessments cannot be disturbed under section 153A on the basis of other material. Pending assessments abate on search, and reassessment under sections 147 and 148 remains available only if their statutory conditions are met. The text states that this position follows the Supreme Court's settled ruling and that the Revenue's challenge failed.

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Issues: Scope of assessment under section 153A of the Income-tax Act, 1961 in cases where no incriminating material is found during search or requisition, and the extent to which completed or unabated assessments can be disturbed.

Analysis: The legal position was governed by the Supreme Court's authoritative ruling, which held that in search cases the Assessing Officer acquires jurisdiction under section 153A, pending assessments stand abated, and for completed or unabated assessments additions can be made only if incriminating material is found during the search. In the absence of such material, completed assessments cannot be reassessed under section 153A on the basis of other material, though recourse under sections 147 and 148 remains available subject to their statutory conditions.

Conclusion: The scope of assessment under section 153A is confined by the presence of incriminating material in respect of completed or unabated assessments, and the Revenue's appeal was dismissed.

Final Conclusion: The challenge to the Tribunal's order did not succeed, and the question of law was answered in accordance with the Supreme Court's settled position.

Ratio Decidendi: In respect of completed or unabated assessments under section 153A, additions cannot be made in the absence of incriminating material found during search or requisition, although reassessment under sections 147 and 148 remains permissible where statutory conditions are satisfied.

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