2015 (9) TMI 1406

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....r the Appellant: Ms Lakshmi Gurung, Junior Standing Counsel. for the Respondent : Mr Salil Aggarwal and Mr Ravi Pratap Mall, Advocates. ORDER 1. In all these appeals one common question that arises is regarding the justification for the additions made by the Assessing Officer ('AO') in the course of the assessments made pursuant to notices issued to the Assessee under Section 153(A)(1)(a)....

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....s found to be incriminating as far as the Assessee was concerned. The AO also considered the reply of the Assessee to a query letter dated 14th November, 2008 of the AO and stated "no adverse view is taken on this score." 5. With the above being admitted factual position, the decision of this Court dated 28th August, 2015 in ITA Nos. 707, 709 and 713 of 2014 (CIT v. Kabul Chawla) would apply on....

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....ers in respect of the six years previous to the relevant AY in which the search takes place. The AO has the power to assess and reassess the 'total income' of the aforementioned six years in separate assessment orders for each of the six years. In other words there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income wo....

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....eted assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfere....