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In view of the second proviso to Section 153A (1) of the Act, once assessment get abated it is opened both way i.e. for the Revenue to make any additions apart from seized material even regular items declared in the return can be subject matter if there is doubt about the genuineness of those items and similarly the assessee also can lodge new claim, deduction or exemption or relief which remained to be claimed in regular return of income, because assessment was never made in thecaseof the assessee in such situation.

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Sec. 153A of Income Tax Act, 1961— Assessment—Pr. CIT vs. JSW STEEL LTD.[2020] 22 ITCD Online 07 (BOM)

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