In Brief
The Supreme Court clarified the scope of assessment under section 153A of the Income Tax Act following a search or requisition. When a search is conducted, all pending assessments automatically abate, and the AO can assess total income for six preceding assessment years. However, for completed assessments with no pending proceedings, the AO can only make additions based on incriminating material actually found during the search. Without such incriminating material, completed assessments cannot be reopened under section 153A. The Court rejected the Revenue's argument that AO could assess total income based on other material sources. This safeguard prevents arbitrary reopening of finalized assessments and ensures that section 153A's special procedure remains connected to its stated purpose: bringing undisclosed income discovered through search into tax.
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