Assessment jurisdiction under the search-assessment proviso was...

Assessment jurisdiction under the search-assessment proviso was held invalid where seized material did not demonstrably show escaped income represented as an asset, so the proviso could not be invoked for a completed earlier year. References to a Valuation Officer to estimate builder construction expenditure were outside the statutory scope as those costs were revenue/stock-in-trade and no prima facie material under parallel unexplained income provisions existed. Valuation reports issued or served after the mandatory six-month period were treated as time-barred and inadmissible. Retracted confessional statements not confronted and without cross-examination were excluded; unsecured loan proof discharged the initial onus and the additions were deleted.

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