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Extended reassessment beyond six years from a search requires...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expenditure.
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Extended reassessment beyond six years from a search requires material showing that escaped income is represented in the form of an asset. Additions for unexplained money and unexplained expenditure cannot support the extended period where they are not founded on an asset discovered during the search; a statement recorded during search does not, by itself, satisfy that statutory condition. On that basis, the reopening was invalid, the additions remained deleted, and the Revenue's appeal was dismissed. The assessee's cross-objection was infructuous.
Extended reassessment beyond six years from a search requires material showing that escaped income is represented in the form of an asset. Additions for unexplained money and unexplained expenditure cannot support the extended period where they are not founded on an asset discovered during the search; a statement recorded during search does not, by itself, satisfy that statutory condition. On that basis, the reopening was invalid, the additions remained deleted, and the Revenue's appeal was dismissed. The assessee's cross-objection was infructuous.
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