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TMI Blog2023 (9) TMI 1166X X X X Extracts X X X X X X X X Extracts X X X X ..... ding Counsel. For the Respondent Through: Mr Bhupinderjeet Singh, Adv. CM Appl.8570/2021 [Application moved on behalf of the appellant/revenue seeking condonation of delay of 113 days in filing the appeal] 1. This is an application filed on behalf of the appellant/revenue, seeking condonation of delay in filing the appeal. 2. According to the appellant/revenue, there is a delay of 113 days. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... took place at the respondent/assessee's premises on 12.01.2012 and 11.09.2013. 9. The record also shows that notices under Section 153A of the Act were issued on 08.07.2013 and 25.11.2014. 10. The record further discloses that on 23.03.2016, the assessment qua aforementioned AY under Section 153A was completed vis-à-vis the respondent/assessee. 11. The assessed income of the respondent/a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee is obliged to file returns for the six assessment years immediately proceeding the previous year relevant to the assessment year in which the search took place. Insofar as the completed assessment as on the date of the search are concerned, the same are to be repeated as increased by additions, only if, based on incriminating material found during the course of search. In other words, i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... view. Sans the incriminating material, no addition could have been made by the AO with regard to the AY in issue, as it was a case of completed assessment. 14.1. This issue stands covered by the judgment rendered by the coordinate bench of this court in CIT vs. Kabul Chawla, (2016) 380 ITR 573. This judgment has received the imprimatur of the Supreme Court in Principal Commissioner of Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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