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Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
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