That even though the appeals of the Revenue are dismissed in respect of assessments passed under 153A and 153C, in the absence of incriminating material found during the search, in respect of such income which was found to have escaped assessment other than through incriminating material, the assessing officers would be entitled to reassess such income in terms of Section 147/148 read with section 150. In view of the above and without further entering into the merits of the application and/or expressing anything on merits on the prayers sought in the present application, the present application is not entertained and we relegate the Revenue to file an appropriate review application seeking the reliefs which are sought in the present application and as and when such review application is filed the same be heard and decided and disposed of in the open court. With this present application stands disposed of.
Case Title: PR. COMMISSIONER OF INCOME TAX CENTRAL 3 Vs. ABHISAR BUILDWELL P. LTD. (2023 INSC 529)
Case Number: MA-000680 / 2023
