S. 153B : Assessment-Search-Time limit-Limitation-Last panchanama-Subsequent panchnama revoking prohibitory order without seizure of material-Time limit is not extended-Restraint order not lifted within one month of assessment order-Central Board Of Direct Taxes instruction-Release of prohibitory order,panchnama and assessment order is invalid-Central Board Of Direct Taxes Circular, Dated 3-7-2002-Last panchnama cancellation of restraint order-Second Panchnama is not last panchnama of conclusion of search-Electronic documents used as evidence-Mandatory conditions of Section 65B of Indian Evidence Act is not complied with-Not admissible evidence-Bogus purchases-Cash purchase of tobacco from grey market-Estimation of profit at 12.5 Per Cent. is proper. [S. 132(3), 132(8A), 143(3) 153A, Indian Evidence Act, 1872, S.65B (2)(d), 65B(4)]
Polisetty Somasundaram v. Dy. CIT (2024) 115 ITR 548 (Visakhapatnam) (Trib)