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Absence of incriminating material during search precludes additions in completed assessments, as per Supreme Court's ruling in Principal Commissioner of Income-tax, Central-3 Vs. Abhisar Buildwell (P.) Ltd. However, completed/unabated assessments can be reopened by the Assessing Officer u/s 147/148, subject to fulfilling prescribed conditions. The High Court clarified that while no additions can be made without incriminating evidence from search/requisition, reopening of assessments is permissible if statutory requirements u/s 147/148 are met. Contentions regarding reopening were expressly kept open.
Absence of incriminating material during search precludes additions in completed assessments, as per Supreme Court's ruling in Principal Commissioner of Income-tax, Central-3 Vs. Abhisar Buildwell (P.) Ltd. However, completed/unabated assessments can be reopened by the Assessing Officer u/s 147/148, subject to fulfilling prescribed conditions. The High Court clarified that while no additions can be made without incriminating evidence from search/requisition, reopening of assessments is permissible if statutory requirements u/s 147/148 are met. Contentions regarding reopening were expressly kept open.
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