2020 (12) TMI 826

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..... ICE J.B.PARDIWALA 1. This appeal under Section 260A of the Income Tax Act, 1961 (for short "the Act, 1961") is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Rajkot Bench, Rajkot dated 27th November, 2019 in the ITA No. 125/RJT/2015 for the A.Y. 2006-07. The Revenue has proposed the following three questions of law for the considerati .....

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..... the previous year in which the search was initiated? (3) Whether the Appellate Tribunal has erred in law and on facts in not considering the scope of the term "total income" as defined in section 2(45) read with section 5 of the Act while holding that no addition/disallowance can be made on issues other than those based on documents or evidences recovered during a search or from a requisition?" .....

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..... the learned Senior Counsel appearing for the Revenue invited our attention to certain observation made by the Appellate Tribunal in para-11 of the impugned judgment. In para-11, the Tribunal has observed that as such, there is no differentiation found in the intent of the Legislature to discriminate whether the assessments were originally framed under Section 143(1) or Section 143(3) or Section 14 .....

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