JUDGMENT :

Surya Prakash Kesarwani, J.

1. All these appeals are admitted on the following substantial questions of law :-

(i) Whether assessment or re-assessment under Section 153-A of the Income Tax Act 1961, can be framed only on the basis of incriminating material found during course of search under section 132 of the Act.

(ii) Whether assessment or re-assessment under Section 153-A of the Income Tax Act 1961 can be framed where no incriminating material has been found in the search under Section 132 of the Act.

2. Since substantial questions of law involved in all these appeals are similar, therefore, all these appeals have been heard together.

Facts:-

3. The facts with regard to disclosed and assessed income of the assessees involved in the ''First Set' of appeals are briefly described as under:-