Restoring Discipline to Search Assessments

Search assessments are not a blank cheque for reopening the past. This case is a sharp reminder that Section 153A draws a hard jurisdictional line between pending and completed assessments, and that line cannot be crossed without incriminating material found in the assessee’s own search. Reliance on third-party statements, inferential computations, or reconstructed narratives may raise suspicion, but suspicion is not evidence. At its core, the ruling reinforces a simple but powerful principle: finality of assessment is a substantive right, not a procedural courtesy. Where completed years are concerned, search powers must operate within evidentiary discipline, not retrospective review. Quick look by J the App by JustIDT