AdvertisementSiddharth Gupta Vs PCIT (Supreme Court of India) The matter arose from two sets of Revenue appeals before the Allahabad High Court against common orders of the Income Tax Appellate Tribunal (ITAT) concerning assessments made under Section 153A of the Income-tax Act, 1961 following search and seizure operations under Section 132. The High Court admitted the appeals on two substantial questions of law: (i) whether assessment or reassessment under Section 153A can be framed only on the basis of incriminating material found during the search, and (ii) whether such assessment can be framed where no...