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opening of the assessments for six previous years is found that the invocation of section 153A would be justified. It was submitted that SLP preferred by the Revenue against the aforesaid decision has been dismissed in 257 Taxman 441 (SC). He further relied upon the decision of the Gujarat High Court in the case of PCIT vs. Somaya Construction Pvt. Ltd.: 387 ITR 529 and various other decisions. Insofar as the reliance placed by the ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 CIT(Appeals) on the decision of the Allahabad High Court in the case of CIT vs. Rajkumar Arora: 52 taxmann.com 172 is concerned, it was submitted that the decision of the jurisdictional High Court in Kabul Chawla (supra) is binding, in preference to the order of the Hon'ble Allahabad High Court. 3.4 In view of the aforesaid arguments, the Ld. Counsel contended the addition of Rs.4,90,20,749 made by the assessing officer in assessment year 2006-07 de-hors any material/document found during the course of search is clearly outside the scope of proceedings under section 153A of the IT Act and is, therefore, illegal and bad in law and hence calls for being deleted on this preliminary ground itself. He prayed that the assessment order be annulled on this ground. 3.5 On merits, the Ld. Sr. Counsel contended that the assessee repeatedly and categorically asserted that the assessee did not maintain any bank account with HSBC, Geneva. Further, it was also repeatedly submitted that no adverse inference should be drawn against the assessee merely on the basis of some loose unauthenticated pieces of paper in the possession of the Revenue, which were shown to the assessee during the course of search, source whereof was also not known/ credible. He ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 submitted that despite the fact that the assessee had no concern/ connection with the aforesaid piece of paper shown to him at the time of search, merely to avoid entering into protracted/ costly litigation with the Income Tax Department and particularly having regard to the fact that the tax liability on the basis of the said paper was informed at the time of search to be around Rs.2 crores, the assessee agreed to voluntarily offer for tax income equivalent to US $11.46 lacs. The said offer was made only in the spirit of settlement and to avoid litigation, without prejudice to the primary contention of the assessee that the said unsigned/ undated piece of paper did not belong/ pertain to him. The aforesaid facts were placed on record vide letter dated 09.02.2012 filed before JCIT (OSD), Jhandewalan Extension, New Delhi. He also referred to the note appended to the return of income and letter dated 30.11.2012 filed with the return. He submitted that the assessing officer, without taking into consideration the fact that the amount of US$ 11,46,368 was offered to tax by the assessee in the return of income filed for the assessment year 2012-13, merely to buy peace and to avoid litigation, made once again, addition of amount equivalent to US $11,02,829 in the assessment year under consideration. ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 3.6 The ld. Sr. Counsel further submitted that the entire case of the assessing officer is based on certain unsigned/ undated/ unauthenticated loose pieces of papers, which was for the first time shown to the assessee at the time of search and copy whereof was given subsequently at the time of recording of statement on 11.12.2014. Analyzing the said document, it was submitted that even the contents of the unsigned/ undated/ unauthenticated loose pieces of papers nowhere establish that the said papers and/ or amounts mentioned therein belonged/ pertained to the assessee. It was submitted that: (a) the paper nowhere refers to the name of any bank, leave aside containing complete particulars of the so-called bank in Geneva; (b) in the entire assessment order, the assessing officer has not mentioned the source wherefrom the aforesaid unsigned/ undated/ unauthenticated loose pieces of papers have been received; (c) in the assessment order it is vaguely mentioned that "document has been received as a part of tax information exchange treaty between Government of India and other countries", without even bothering to mention the name of the country from which the information has been received. He vehemently contended that the assessing officer failed to appreciate that :- (a) the assessee ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 repeatedly and categorically asserted that the alleged foreign bank account did not belong to the assessee; (b) none of the deposits, as alleged, related to the assessee; and (c) no transaction was made by the assessee, and therefore, the question of making any addition in the hands of the assessee could not at all arise. He submitted that the assessing officer erred in law in drawing adverse inference against the assessee merely on the basis of general particulars of the assessee (which are available in public domain) appearing in some unsigned/ undated/ unauthenticated loose pieces of papers, more so when the assessing officer had categorically admitted in para 10 of the impugned order that 'authentic information/communication' regarding the alleged foreign bank account was still awaited from the Swiss Authorities. He stated that even in the statement of the assessee recorded by the assessing officer on 11.12.2014 during the course of assessment proceedings, the assessee categorically asserted that the assessee did not own any bank account in HSBC, Geneva, Switzerland and categorically denied having any connection with the alleged bank account. He thus submitted that the assessee has time and again asserted that the assessee does not have any bank account in HSBC Bank, Geneva, ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 Switzerland and also stated that the paper does not appear to be "pertaining to any bank as name of the bank does not appear in this document". The assessee also clarified that the assessee has neither opened nor authorized anyone to open any bank account in HSBC Bank, Geneva and that the assessee had nothing to do with the unsigned/ unauthenticated pieces of paper. On the non- furnishing of the consent/declaration form, he submitted that the assessee had repeatedly and categorically asserted that since the alleged account in HSBC, Geneva, Switzerland did not belong/ pertain to him, the assessee was not at all competent to sign any form/ declaration in relation to the same. He then took us through assessment order and gave a para-wise rebuttal of the assessment order.