Dismissing the appeal of the Revenue the Court held that in the absence of any incriminating material, the completed assessment cannot be reiterated and abated assessment or reassessment .Court also held that sale and purchase of agricultural land held to be bogus / sham / paper transactions . Judgement of Supreme Court rendered after the assessment cannot be said to be incriminating . (AY. 2001 -02 to 2003 -04 )
PCIT v. PCF Ltd ( 2022) 220 DTR 467/ (2023) 330 CTR 89 ( Delhi )( HC)
S. 153A: Assessment – Search or requisition-No incriminating material was found – Sale and purchase of agricultural land held to be bogus / sham / paper transactions -Judgement of Supreme Court rendered after the assessment cannot be said to be incriminating – Order of the Tribunal is affirmed [ S.132(4), 260A ]