2024 (8) TMI 1503

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....grieved by the judgment dated 17 April 2023, posits the following questions of law for our consideration: "2.1 Whether on facts and circumstances of the case, Ld. ITAT has erred in not treating the statement under section 132(4) as incriminating in nature and thereby deleting the addition of Rs. l1,87,39,176/- without going into the merits of the same? 2.2 Whether on facts and circumstances of the case, Ld. ITAT is correct in upholding the decision of Ld. CIT(A) on deletion of addition of Rs.43,53,770/- without going into merits of the same? 2.3 Whether on facts and circumstances of the case, Ld. ITAT has erred both on law and facts in declaring the information shared by France with India under relevant provisions of 'exchange of ....

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....ment year in which the search takes place. (ii) Assessments and reassessments pending on the date of the search shall abate. The total income for such assessment years will have to be computed by the Assessing Officers as a fresh exercise. (iii) The Assessing Officer will exercise normal assessment powers in respect of the six years previous to the relevant assessment year in which the search takes place. The Assessing Officer 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 assessment years "in which both the disclosed and the undisclosed income would be br....