V. Ramprasad Raju v. CIT (2021) 86 ITR 33 (SN) (Bang.)(Trib.)

S. 158BC : Block assessment-Undisclosed Income-Share application money-No incriminating material found during search-Addition is held to be not justified-Interest-Delay in filing return-No provision to charge interest beyond date of original assessment. [S.158BFA(1)]

Tribunal held that when no incriminating material was found during search addition cannot be made as undisclosed income.   The Tribunal also held that order passed by the Tribunal earlier and the order passed by the Assessing Officer in the set aside proceedings were a continuation of original assessment proceedings. It was not a case of quashing of the original assessment order and initiation of altogether new proceedings. Further, there was no provision under the Act to extend charging of interest beyond the date of completion of the original assessment proceedings. Hence, the view expressed the Commissioner (Appeals) was correct. (BP. 1990-2001)