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The special leave petition is dismissed on the ground of low tax effect.

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Section 153A of the Income Tax Act, 1961—Search and seizure—Only undisclosed income and undisclosed assets detected during search could be brought to tax in relation to these years for which the notice under section 153A of the Income Tax Act, 1961 has been issued — PR. CIT Vs. CAPRIHANS INDIA LTD. [2020] 269 TAXMAN 385 (SC)

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