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Absence of a Document Identification Number in a section 153D approval did not invalidate the assessment, because the curative rule was read to cover assessment proceedings and connected communications, not only the final order. For the search assessment, the Tribunal held that A.Y. 2015-16 was a completed, unabated assessment and that the seized papers were only disclosed returns, audited accounts and ledger entries; no incriminating material was found, so section 153A could not support an addition. On merits, section 41(1) was held inapplicable because the liability write-back did not reverse any prior tax benefit, as the related losses had lapsed without set-off. The assessee's appeal was partly allowed and the Revenue's appeal was dismissed.
Absence of a Document Identification Number in a section 153D approval did not invalidate the assessment, because the curative rule was read to cover assessment proceedings and connected communications, not only the final order. For the search assessment, the Tribunal held that A.Y. 2015-16 was a completed, unabated assessment and that the seized papers were only disclosed returns, audited accounts and ledger entries; no incriminating material was found, so section 153A could not support an addition. On merits, section 41(1) was held inapplicable because the liability write-back did not reverse any prior tax benefit, as the related losses had lapsed without set-off. The assessee's appeal was partly allowed and the Revenue's appeal was dismissed.
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