https://www.taxtmi.com/caselaws?id=463176 The ITAT Ahmedabad held that the time limit for framing assessment under section 153A read with section 143(3) is 21 months from the end of the financial year in which the last search authorization was executed, as amended by the Finance Act 2016, and not 24 months. The assessment framed beyond this period was quashed as time-barred. The tribunal clarified that the exclusion period under section 153B does not extend but only excludes time, providing a minimum 60-day window for the AO to complete the assessment. Further, additions to income must be based on incriminating material found during the search; absent such material, no additions can be made to disclosed regular income. Consequently, the CIT(A)'s order disallowing additions was upheld. The revision under section 263 was also held unsustainable since the original order was quashed. en-us Wed, 15 Mar 2023 00:00:00 +0530 Mon, 11 Aug 2025 20:56:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463176 The ITAT Ahmedabad held that the time limit for framing assessment under section 153A read with section 143(3) is 21 months from the end of the financial year in which the last search authorization was executed, as amended by the Finance Act 2016, and not 24 months. The assessment framed beyond this period was quashed as time-barred. The tribunal clarified that the exclusion period under section 153B does not extend but only excludes time, providing a minimum 60-day window for the AO to complete the assessment. Further, additions to income must be based on incriminating material found during the search; absent such material, no additions can be made to disclosed regular income. Consequently, the CIT(A)'s order disallowing additions was upheld. The revision under section 263 was also held unsustainable since the original order was quashed. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463176