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The Mumbai Tribunal, in the case of Sunder Agencies vs. DCIT, reported at 63 ITD 245, has held that the Assessing Officer is not given a licence to make roving enquiries, connected with completed assessments in order to determine the undisclosed income. It is beyond his powers to review the completed assessments unless there is some direct material or, direct evidence that comes to his knowledge as a result of the search which indicates clearly the fact of undisclosed income. The provisions of Chapter XIVB do not give the revenue the right to draw presumptions with regard to the undisclosed income.



 
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