Shanti Prime Publication Pvt. Ltd.
Sec. 153A of Income-tax Act, 1961— Search and seizure—In view of the second proviso to s. 153A(1), once assessment gets abated, it is open for the assessee to lodge a new claim in a proceeding under s. 153A(1) which was not claimed in his regular return of income, because assessment was never made/finalised in the case of the assessee in such a situation. Pending assessment or reassessment on the date of initiation of search if abated, then the assessment pending on the date of initiation of search shall cease to exist and no further action with respect to that assessment shall be taken by the AO and in such a situation the assessment is required to be undertaken by the AO under s. 153A(1) of the said Act — Pr. Cit vs. JSW Steel Ltd. [2020] 313 CTR 129 (BOM)