https://www.taxtmi.com/caselaws?id=784252 Search assessments for two AYs were held time-barred under s 153B because the legally effective conclusion of search was the panchanama drawn when the authorised officer completed physical search and left the premises; subsequent panchanamas prepared only to lift restraints under s 132(3), without fresh authorisation and without any further search activity, could not extend limitation, particularly as the restraints lacked recorded "not practicable" reasons and were revoked beyond CBDT's binding one-month directive. Consequently, both assessment orders were quashed as barred by limitation. Independently, approval under s 153D was held mechanical, showing no examination of seized material, rendering the assessments unsustainable. On merits, additions/disallowances (alleged unaccounted receipts, construction, interest, cash payments, trustee-related repayment, pandemic/renovation expenses, donation, depreciation) were deleted for want of cogent evidence and incorrect application of non-trust provisions. en-us Wed, 26 Nov 2025 00:00:00 +0530 Wed, 31 Dec 2025 12:58:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784252 Search assessments for two AYs were held time-barred under s 153B because the legally effective conclusion of search was the panchanama drawn when the authorised officer completed physical search and left the premises; subsequent panchanamas prepared only to lift restraints under s 132(3), without fresh authorisation and without any further search activity, could not extend limitation, particularly as the restraints lacked recorded "not practicable" reasons and were revoked beyond CBDT's binding one-month directive. Consequently, both assessment orders were quashed as barred by limitation. Independently, approval under s 153D was held mechanical, showing no examination of seized material, rendering the assessments unsustainable. On merits, additions/disallowances (alleged unaccounted receipts, construction, interest, cash payments, trustee-related repayment, pandemic/renovation expenses, donation, depreciation) were deleted for want of cogent evidence and incorrect application of non-trust provisions. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784252