Kawaljit Singh v. ACIT (2024) 204 ITD 307 (Chd)( Trib)

S.153A: assessment – Search – Less than 50 lakhs – Assessment beyond six years is bad in law . [ S.69, 132 ]

Held that  the assessment beyond six years but not more than ten years can be reopened u/s 153A of the Act only if the AO is in possession of evidence depiciting the escapement of income more than 50 lakhs . Tribunal held that such provision extending the scope of assessment beyond six years from the date of search has to be constructed strictly and the evidence relied upon by the AO in such assessment of extended period must be tangible evidence. Appeal is allowed . ( AY. 2011-12)