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    Case LawsIncome Tax
    Search, Seizure, and Total Income: Interpreting Section 153A in Light of Incriminating Material - 20...
    Case LawsIncome Tax
    Section 153A of the Income Tax Act: A Critical Analysis of the Supreme Court's Interpretation in the...
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    Case LawsIncome Tax
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    Search assessments under section 153A permit full reassessment for abated years but limit reopened completed years to incriminating search material.
    Section 153A's assessment power is search-linked: for abated years the AO may reassess total income afresh, but for completed/unabated years additions under section 153A are permissible only where specific incriminating material relating to that year is found during the search; absent such material, disturbance of a completed assessment must proceed, if at all, under sections 147-148 subject to their conditions.
    Case LawsIncome Tax
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    Scope of assessment post-search: completed assessments permit additions only from incriminating material found during searches.
    The Supreme Court clarified that for assessments completed before a search, the Assessing Officer's power to reassess within the retrospective period is constrained: any additions in such completed assessments must be based on incriminating material discovered during the search, thereby limiting use of search powers to matters tied to the unearthed evidence and preventing expansion of assessments on unrelated material.

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      ActsIncome Tax