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Corporate TaxArticle·23 March 2026

ITAT Reaffirms the Sanctity of Completed Assessments

By J the App

Executive Summary

This ruling underscores a critical limitation on the powers of the Assessing Officer in search assessments. 

Where an assessment has attained finality, it cannot be reopened under Section 153A unless supported by incriminating material found during search. 

The Tribunal held that merely re-examining previously adjudicated issues, without new evidence, is impermissible in law. 

The decision strengthens taxpayer protection against arbitrary reassessment and reinforces judicial discipline in search-related proceedings.


The present case arises from an appeal filed by the Revenue before the Chennai Bench of the Income Tax Appellate Tribunal against the order of the Commissioner of Income Ta...

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