1. “INCOME-TAX – INSIGHT TO THE ASSESSMENT OF INCOME TAX”
By Shri A.D. Mehrotra, CCIT, Surat

2. RETURN OF INCOME
It is mandatory for every taxpayer to communicate the details of his income to the Income-tax Department. These details are to be furnished in the prescribed form known as return of income.

3. Persons required to file the Return of Income
The provisions relating to filing of return of income depend upon the status of the taxpayer. The position in this regard is given below:
In the case of companies:
It is mandatory for every company to file the return of income irrespective of its income or loss.
In the case of partnership firms:
It is mandatory for every partnership firm to file the return of income irrespective of its income or loss.
In the case of an Individual/HUF/AOP/BOI/Artificial Juridical Person:
Such person has to file the return of income if its total income (including income of any other person in respect of which he is assessable) without giving effect to the provisions of section 10(38), 10A, 10B or 10BA or Chapter VIA (i.e., deduction under section 80C to 80U), exceeds the maximum amount which is not chargeable to tax i.e. exceeds the exemption limit.

4. Persons required to file the Return of Income
In the case of charitable or religious trusts:
Every person in receipt of income derived from property held under charitable or religious trusts/legal obligations or in receipt of income being voluntary contributions referred to in section 2(24)(iia), has to file the return of income if its total income without giving effect to the provisions of sections 11 and 12 exceeds the maximum amount not chargeable to income-tax.
In the case of political parties:
The Chief Executive Officer of every political party has to file the return of income of the party if the total income of the party without giving effect to the provisions of section 13A exceeds the maximum amount not chargeable to income-tax.

5. Persons required to file the Return of Income
In the case of certain associations :
Following entities are liable to file the return of income if their total income without giving effect to the provisions of section 10 exceeds the maximum amount not chargeable to tax:
 Research association referred to in section 10(21)
 News agency referred to in section 10(22B)
 Association or institution referred to in section 10(23A)
 Person referred to in clause (23AAA) of section 10.
 Institution referred to in section 10(23B)
 Fund/institution/trust/university/other educational institution/any hospital/medical institution referred to in sub-clause (iiiac), (iiiab), (iiiad), (iiiae), (iv), (v), (vi) or (via) of section 10(23C)
 Mutual Fund referred to in clause (23D) of section 10
 Securitisation trust referred to in clause (23DA) of section 10
 Investor Protection Fund referred to in clause (23EC) or clause (23ED) of section 10.
 Core Settlement Guarantee Fund referred to in clause (23EE) of section 10
 Venture capital company or venture capital fund referred to in clause (23FB) of section 10;
 Trade union/association referred to in sub-clause (a) or (b) of section 10(24)
 Board or Authority referred to in clause (29A) of section 10.
 Body/authority/Board/Trust/Commission referred to in section 10(46)
 Infrastructure debt fund referred to in section 10(47)

6. Persons required to file the Return of Income
In the case of certain university, college or other institution:
Every university, college or other institution referred to in clause (ii) and clause (iii) of section 35(1), which is not required to furnish return of income or loss under any other provision of the Act, shall furnish the return of income every year, irrespective of income (or) loss.
In the case of Business Trust :
Every business trust, which is not required to furnish return of income or loss under any other provision of the Act, shall furnish the return of income every year, irrespective of income (or) loss.
-In case of investment fund referred to in section 115UB:
Every investment fund referred to in section 115UB, which is not required to furnish return of income or loss under any other provisions, shall furnish the return of income in respect of its income or loss every year irrespective of income (or) loss.

7. Persons required to file the Return of Income
In the case of persons holding assets located outside India:
A person, being a resident in India (other than not ordinarily resident), who is not required to furnish a return under any of the above `and who at any time during the previous year :
(a) holds, as a beneficial owner (*) or otherwise, any asset (including any financial interest in any entity) located outside India or has signing authority in any account located outside India; or
(b) is a beneficiary (*) of any asset (including any financial interest in any entity) located outside India,
shall furnish, on or before the due date, a return in respect of his income or loss for the previous year in such form and verified in such manner and setting forth such other particulars as may be prescribed. However, above discussed provision will not apply to an individual, being a beneficiary of any asset (including any financial interest in any entity) located outside India where, income, if any, arising from such asset is includible in the income of the person referred to in (a) above.
(*) "Beneficial owner" in respect of an asset means an individual who has provided, directly or indirectly, consideration for the asset for the immediate or future benefit, direct or indirect, of himself or any other person.
(*) "Beneficiary" in respect of an asset means an individual who derives benefit from the asset during the previous year and the consideration for such asset has been provided by any person other than such beneficiary.

8. Due date of filing of return of income
Sr. No.
Status of the Taxpayer
Due Date 1
Any company other than a company who is required to furnish a report in Form No. 3CEB under section 92E (i.e. other than covered in 2 below)
September 30 of the assessment year 2
Any person (may be corporate/non corporate) who is required to furnish a report in Form No. 3CEB under section 92E
November 30 of the assessment year 3
Any person (other than a company) whose accounts are to be audited under the Income-tax Law or under any other law 4
A working partner of a firm whose accounts are required to be audited 5under this Act or under any other law
September 30 of the assessment 5
Any other assessee
July 31 of the assessment year

9. Belated return:
If the person fails to file the return of income within the time-limit prescribed in this regard, then as per section 139(4) he can file a belated return. A belated return can be filed at any time before the end of the relevant assessment year or before completion of assessment, whichever is earlier.

10. Consequences of delay in filing the return of income:
Delay in filing the return of income may attract following consequences:
 Loss (other than loss under the head “Income from house property”) cannot be carried forward.
 Levy of interest under section 234A.
 Levy of fee under section 234F*.
 Exemptions/deductions under sections 10A, 10B, 80-IA, 80-IAB, 80-IB, 80-IC, 80-ID and 80-IE are not available.
*w.e.f. assessment year , if assessee failed to furnish return of income within due date as prescribed in section 139(1) then he is required to pay:-
a) Rs if return is furnished on or before 31 December of assessment year.
b) Rs. 10,000 in any other case.
however, if total income of the person does not exceeds Rs. 5 lakh then fee payable shall be Rs

11. Revision of return:
A return can be revised at any time before the end of the relevant assessment year or before the completion of the assessment, whichever is earlier. It should be noted that only a return filed under section 139(1) or belated return filed under section 139(4) can be revised.
Return of income filed pursuant to notice under section 142(1) of Act cannot be revised under section 139(5).

12. Defective return:
If the Assessing Officer finds the return of income to be defective under section 139(9), then he may intimate such defect to the taxpayer and may give an opportunity to him to rectify such defect.
The taxpayer shall rectify such defect in the return of income within a period of 15 days of such intimation or within such further period as the Assessing Officer may allow. Failing to comply with the direction within stipulated time, the return shall be treated as an invalid return and the provisions of the Act shall apply as if the taxpayer had failed to furnish the return.

13. Return to be verified by whom:
As per section 140, the return of income is to be verified by:
a) In the case of an individual :
i. by the individual himself;
ii. where he is absent from India, by the individual himself or by some person duly authorised by him in this behalf;
iii. where he is mentally incapacitated from attending to his affairs, by his guardian or any other person competent to act on his behalf; and
iv. where, for any other reason, it is not possible for the individual to verify the return, by any person duly authorized by him in this behalf:
b) in the case of a Hindu undivided family, by the karta, and, where the karta is absent from India or is mentally incapacitated from attending to his affairs, by any other adult member of such family;
c) in the case of a company, by the managing director thereof, or where there is no managing director, by any director thereof.

14. Return to be verified by whom:
(d) in the case of a firm, by the managing partner thereof, or where there is no managing partner as such, by any partner thereof, not being a minor;
(e) in the case of a limited liability partnership, by the designated partner thereof, or where there is no designated partner as such, by any partner thereof;
(f) in the case of a local authority, by the principal officer thereof;
(g) in the case of a political party referred to in section 139(4B), by the chief executive officer of such party;
(h) in the case of any other association, by any member of the association or the principal officer thereof; and
(i) in the case of any other person, by that person or by some person competent to act on his behalf.

15. ITR Forms prescribed for filing of Return for A.Y. 2018-19
Description
ITR-1 SAHAJ
For individuals being a resident other than not ordinarily resident having Income from Salaries, one house property, other sources (Interest etc.) and having total income upto Rs. 50 lakh
ITR 2
For Individuals and HUFs not having income from profits and gains of business or profession
ITR 3
For individuals and HUFs having income from profits and gains of business or profession
ITR 4 (Sugam)
For Presumptive Income from Business & Profession
ITR 5
For persons other than,- (i) individual, (ii) HUF, (iii) company and (iv) person filing Form ITR-7
ITR 6
For Companies other than companies claiming exemption under section 11
ITR 7
For persons including companies required to furnish return under sections 139(4A) or 139(4B) or 139(4C) or 139(4D) or 139(4E) or 139(4F)

16. Modes of filing the return of income:
Return Forms can be filed with the Income-tax Department in any of the following ways, -
(i) by furnishing the return in a paper form;
(ii) by furnishing the return electronically under digital signature;
(iii) by transmitting the data in the return electronically under electronic verification code;
(iv) by transmitting the data in the return electronically and thereafter submitting the verification of the return in Return Form ITR-V;
Note: Where the return of income is filed in the manner given at (iv) without digital signature, then the taxpayer should take two printed copies of Form ITR-V. One copy of ITR-V, duly signed by the taxpayer, is to be sent (within the period specified in this regard, i.e., 120 days) by ordinary post or speed post to “Income-tax Department – CPC, Post Bag No. 1, Electronic City Post Office, Bengalore– (Karnataka). The other copy may be retained by the taxpayer for his record.

17. Modes of filing the return of income:
The ITRs are to be filed electronically except where return is furnished in ITR Form-1 (Sahaj) or ITR-4 (Sugam), the following persons have an option to file return in paper form:
(i) An individual of the age of 80 years or more at any time during the previous year; or
(ii) An individual or HUF whose income does not exceed five lakh rupees and who has not claimed any refund in the Return of Income.

18. Applicability of ITR – 1 (SAHAJ)
Return Form ITR – 1 (SAHAJ) can be used by an individual whose total income includes:
Income from salary/pension; or
Income from one house property (excluding cases where loss is brought forward from previous years); or
Income from other sources (excluding winnings from lottery, income from race horses and income taxable under section 115BBDA or Income of the nature referred to in section 115BBE).
Further, in a case where the income of another person like spouse, minor child, etc., is to be clubbed with the income of the taxpayer, this return form can be used only when such income falls in any of the above categories.

19. Applicability of ITR – 2 Applicability of ITR – 3
This Return Form is to be used by an individual or an Hindu Undivided Family who is not eligible to file Sahaj ITR-1 and whose income chargeable to income-tax under the head “Profits or gains of business or profession” is in the nature of interest, salary, bonus, commission or remuneration, by whatever name called, due to, or received by him from a partnership firm.
in a case where the income of another person like spouse, minor child, etc., is to be clubbed with the income of the taxpayer, this Return Form can be used if income to be clubbed falls in any of the above categories.
Applicability of ITR – 3
Form ITR – 3 can be used by an individual or a Hindu Undivided Family who is carrying on a proprietary business or profession.

20. Applicability of ITR – 4 (SUGAM)
Form ITR – 4 (SUGAM) can be used by an individual/HUF/Firm whose total income for the year includes :
Business income computed as per the provisions of section 44AD or 44AE; or
Income from profession computed as per the provisions of section 44ADA; or
Income from salary/pension; or
Income from one house property (excluding cases where loss is brought forward from previous years); or
Income from other sources (excluding winnings from lottery and income from race horses).
in a case where the income of another person like spouse, minor child, etc., is to be clubbed with the income of the taxpayer, this return form can be used where income to be clubbed falls in any of the above categories.

21. Applicability of ITR – 5 Applicability of ITR – 6
Form ITR – 5 can be used by a person being a firm, LLP, AOP, BOI, artificial juridical person referred to in section 2(31)(vii), cooperative society and local authority.
Applicability of ITR – 6
Form ITR – 6 can be used by a company, other than a company claiming exemption under section 11 (exemption under section 11 can be claimed by a charitable/religious trust).
Applicability of ITR – 7
Form ITR – 7 can be used by persons including companies who are required to furnish return under section 139(4A) or section 139(4B) or section 139(4C) or section 139(4D) or section 139(4E) or section 139(4F) (i.e., trusts, political parties, institutions, colleges, investment fund etc.).

22. Source for obtaining the return forms
The return forms (ITR forms) can be downloaded from
Procedure for e-filing the return of income
Income-tax Department has established an independent portal for e-filing the return of income. The taxpayers can log on to for e-filing the
return of income.
E-filing utility provided by the Income-tax Department
The Income-tax Department has provided free e-filing utility (i.e., software) to generate e-return and furnishing the return electronically. The e-filing utility provided by the Department is simple, easy to use and also contains instructions on how to use it. By using the e-filing utility, the taxpayers can easily file their return of income. Utility can be downloaded from
Benefits of e-filing the return of income
E-filing can be done from any place at any time and it saves time and efforts. It is simple, easy and faster. The e-filed returns are generally processed faster as compared to returns
filed manually.

23. Form 26AS A taxpayer may pay tax in any of the following forms:
Tax Deducted at Source (TDS)
Tax Collected at Source (TCS)
Advance tax or Self-assessment Tax or Payment of tax on regular assessment. The Income-tax Department maintains the database of the total tax paid by the taxpayer (i.e., tax credit in the account of a taxpayer). Form 26AS is an annual statement maintained under Rule 31AB of the Income-tax Rules disclosing the details of tax credit in the account of the taxpayer as per the database of Income-tax Department. In other words, Form 26AS will reflect the details of tax credit appearing in the Permanent Account Number of the taxpayer as per the database of the Income-tax Department. The tax credit will cover TDS, TCS and tax paid by the taxpayer in other forms like advance tax, Self-assessment tax, etc.
Income-tax Department generally allows a taxpayer to claim the credit of taxes as reflected in his Form 26AS

24. VARIOUS ASSESSMENTS UNDER THE INCOME TAX LAW
Every taxpayer has to furnish the details of his income to the Income-tax Department. These details are to be furnished by filing up his return of income. Once the return of income is filed up by the taxpayer, the next step is the processing of the return of income by the Income Tax Department. The Income Tax Department examines the return of income for its correctness. The process of examining the return of income by the Income-Tax department is called as “Assessment”. Assessment also includes re-assessment and best judgment assessment under section 144.
Under the Income-tax Law, there are four major assessments given below:
Assessment under section 143(1), i.e., Summary assessment without calling the assessee.
Assessment under section 143(3), i.e., Scrutiny assessment.
Assessment under section 144, i.e., Best judgment assessment.
Assessment under section 147, i.e., Income escaping assessment.
Assessment under section 153A of the Act, i.e. search assessment
Assessment under section 153C of the Act i.e. search assessment

25. Assessment under section 143(1)
This is a preliminary assessment and is referred to as summary assessment without calling the assessee (i.e., taxpayer).
Scope of assessment under section 143(1)
Assessment under section 143(1) is like preliminary checking of the return of income. No detailed scrutiny of the return of income is carried out. The total income or loss is computed after making the following adjustments (if any), namely:-
(i) any arithmetical error in the return; or
(ii) an incorrect claim , if such incorrect claim is apparent from any information in the return;
(iii) disallowance of loss claimed, if return of the previous year for which set-off of loss is claimed was furnished beyond the due date specified under sectionc 139(1); or
(iv) disallowance of expenditure indicated in the audit report but not taken into account in computing the total income in the return; or of one year from the end of the financial year in which the return of income is filed.

26. Assessment under section 143(1)
(v) disallowance of deduction claimed u/s 10AA, 80IA to 80-IE, if the return is furnished beyond the due date specified under section 139(1); or
 (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income in the return.
However, no such adjustment shall be made unless an intimation is given to the assessee of such adjustment either in writing or in electronic mode. Further, the response received from the assessee, if any, shall be considered before making any adjustment, and in case where no response is received within 30 days of the issue of such intimation, such adjustments shall be made.
Time-limit
Assessment under section 143(1) can be made within a period of one year from the end of the financial year in which the return of income is filed.

27. Assessment under section 143(3)
This is a limited or complete assessment and is referred to as scrutiny assessment. Limited / detailed scrutiny of the return of income is carried out. Scrutiny cases are selected through Computer Assisted Scrutiny Selection (CASS) on the parameters selected for limited or complete scrutiny, which the case may be. Further, the CBDT also notifies parameters for selection of cases under compulsory scrutiny, from time to time.

28. Sample – Cass Selection Reason and Issue

29. Assessment under section 143(3)
Scope of assessment under section 143(3)
The objective of scrutiny assessment is to confirm that the taxpayer has not understated the income or has not computed excessive loss or has not underpaid the tax in any manner.
To confirm the above, the Assessing Officer carries out a limited or detailed scrutiny of the return of income, as the case may be, and satisfies himself regarding various claims, deductions, etc., made by the taxpayer in the return of income.

30. Assessment under section 143(3)
Procedure of assessment under section 143(3)
To carry out assessment under section 143(3), the Assessing Officer shall serve such notice in accordance with provisions of section 143(2).
-Notice under section 143(2) should be served within a period of six months from the end of the financial year in which the return is filed.
The taxpayer or his representative (as the case may be) will appear before the Assessing Officer and will place his arguments, supporting evidences, etc., on various matters/issues as required by the Assessing Officer.
After hearing/verifying such evidence and taking into account such particulars as the taxpayer may produce and such other evidence as the Assessing Officer may require on specified points and after taking into account all relevant materials which he has gathered, the Assessing Officer, by an order in writing, make an assessment of the total income or loss of the taxpayer and determine the sum payable by him or refund of any amount due to him on the basis of such assessment.

31. Assessment under section 143(3)
Time-limit
As per Section 153, the time limit for making assessment under section 143(3) is:-
Within 21 months from the end of the assessment year in which the income was first assessable. [For assessment year or before]
18 months from the end of the assessment year in which the income was first assessable. [for assessment year ]
12 months from the end of the assessment year in which the income was firstassessable [Assessment year and onwards]
Note:- If reference is made to TPO, the period available for assessment shall be extended by 12 months.

32. Assessment under section 144
This is an assessment carried out as per the best judgment of the Assessing Officer on the basis of all relevant material he has gathered. This assessment is carried out in cases where the taxpayer fails to comply with the following requirements specified in section 144:
If the taxpayer fails to file the return required within the due date prescribed under section 139(1) or a belated return under section 139(4) or a revised return under section 139(5).
If the taxpayer fails to comply with all the terms of a notice issued under section 142(1).
If the taxpayer fails to comply with the directions issued under section 142(2A).
If after filing the return of income the taxpayer fails to comply with all the terms of a notice issued under section 143(2), i.e., notice of scrutiny assessment.
If the assessing officer is not satisfied about the correctness or the completeness of the accounts of the taxpayer or if no method of accounting has been regularly employed by the taxpayer.
From the above criteria, it can be observed that best judgment assessment is resorted to in cases where the return of income is not filed by the taxpayer or if there is no cooperation by the taxpayer in terms of furnishing information / explanation related to his tax assessment or if books of accounts of taxpayer are not reliable or are incomplete.

33. Procedure of assessment under section 144
If the conditions given above calling for best judgment are satisfied, then the Assessing Officer will serve a notice on the taxpayer to show cause why the assessment should not be completed to the best of his judgment.
No notice as given above is required in a case where a notice under section 142(1) has been issued prior to the making of an assessment under section 144.
If the Assessing Officer is not satisfied by the arguments of the taxpayer and he has reason to believe that the case demands a best judgment, then he will proceed to carry out the assessment to the best of his knowledge.
If the criteria of the best judgment assessment are satisfied, then after taking into account all relevant materials which the Assessing Officer has gathered, and after giving the taxpayer an opportunity of being heard, the Assessing Officer shall make the assessment of the total income or loss to the best of his knowledge/judgment and determine the sum payable by the taxpayer on the basis of such assessment.

34. Procedure of assessment under section 144
Time-Limit
As per Section 153, the time limit for making assessment under section 144 is:-
Within 21 months from the end of the assessment year in which the income was first assessable. [For assessment year or before]
18 months from the end of the assessment year in which the income was first assessable. [for assessment year ]
12 months from the end of the assessment year in which the income was first assessable [Assessment year and onwards] 
Note:- If reference is made to TPO, the period available for assessment shall be extended by 12 months.

35. Assessment under section 147
This assessment is carried out if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year.
scope of assessment under section 147:
-The objective of carrying out assessment under section 147 is to bring under the tax net any income which has escaped assessment in original assessment.
Original assessment here means an assessment under sections 143(1), 143(3), 144 and 147 (as the case may be).
In other words, if any income has escaped (*) from being taxed in the original assessment made under section 143(1) or section 143(3) or section 144 or section147, then the same can be brought under tax net by resorting to assessment under section 147.

36. Assessment under section 147
In the following cases, it will be considered as income having escaped assessment:
Where no return of income has been furnished by the taxpayer, although his total income or the total income of any other person in respect of which he is
assessable during the previous year exceeded the maximum amount which is not chargeable to income-tax.
 Where a return of income has been furnished by the taxpayer but no assessment has been made and it is noticed by the Assessing Officer that the taxpayer has
understated the income or has claimed excessive loss, deduction, allowance or relief in the return. 
 Where the taxpayer has failed to furnish a report in respect of any international transaction which he was required to do under section 92E.
 Where an assessment has been made, but: i. income chargeable to tax has been under assessed; or ii. income has been assessed at low rate; or iii. income has been made the subject of excessive relief; or iv. excessive loss or depreciation allowance or any other allowance has been computed;

37. Assessment under section 147
In the following cases, it will be considered as income having escaped assessment:
 Where a person is found to have any asset (including financial interest in any entity) located outside India.
 Where a return of income has not been furnished by the assessee and on the basis of information or document received from the prescribed income-tax authority
under section 133C(2), it is noticed by the Assessing Officer that the income of the assessee exceeds the maximum amount not chargeable to tax.
 Where a return of income has been furnished by the assessee and on the basis of information or document received from the prescribed income-tax authority under
section 133C(2), it is noticed by the Assessing Officer that the assessee has understated the income or has claimed excessive loss, deduction, allowance or relief in the return.

38. Procedure of assessment under section 147:
For making an assessment under section 147, the Assessing Officer has to issue notice under section 148 to the taxpayer and has to give him an opportunity of being heard.
If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, then he may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section. He is also empowered to re-compute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned.
Items which are the subject matters of any appeal, reference or revision cannot be covered by the Assessing Officer under section 147.

39. Time-limit:
As per Section 153, the time limit for making assessment under section 147 is:-
1) Within 9 months from the end of the financial year in which the notice under section 148 was served (if notice is served before ).
2) 12 months from the end of the financial year in which notice under section 148 is served (if notice is served on or after ).
Note:- If reference is made to TPO, the period available for assessment shall be extended by 12 months.

40. Time-limit for issuance of notice under section 148
 Notice under section 148 can be issued within a period of 4 years from the end of the relevant assessment year. If the escaped income is Rs. 1,00,000 or more and certain other conditions are satisfied, then notice can be issued upto 6 years from theend of the relevant assessment year.
In case the escaped income relates to any asset (including financial interest in any entity) located outside India, notice can be issued upto 16 years from the end of the relevant assessment year.
Notice under section 148 can be issued by AO only after getting prior approval from the prescribed authority

41. Assessment in Case of Search or requisition:
S. 153A. - In the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer —
      (a )  issue notice to such person requiring him to furnish within such period, as may be specified in the notice, the return of income in respect of each assessment year falling within six assessment years referred to in clause (b), in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139;
         (b )  assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made :
the Assessing Officer assess or reassess the total income in respect of each assessment year falling within such six assessment years:
-that assessment or reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section pending on the date of initiation of the search under section 132 or making of requi­sition under section 132A, as the case may be, shall abate.

42. S. 153B - Time-limit for completion of assessment under section 153A;
in respect of each assessment year falling within six assessment years referred to in clause (b) of section 153A, within a period of two years from the end of the financial year in which the last of the authorisations for search under section 132 or for requisition under section 132A was executed;
 in respect of the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A, within a period of two years from the end of the financial year in which the last of the authorisations for search under section 132 or for requisition under section 132A was executed.
153C.  Assessment of income of any other person:
where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed against each such other person and issue such other person notice and assess or reassess income of such other person in accordance with the provisions of section 153A.’.