Unabated search assessment requires year-specific incriminating material; presumptive cash additions and section 69A disallowance failed here.

In an unabated search assessment, additions for alleged unaccounted cash from immovable property transfers could not be sustained for the relevant assessment years because the loose sheet was dated to a different year and no incriminating material linked it to those years. The addition under section 69A also failed because the seized documents did not show the assessee as owner, beneficiary, or recipient of the alleged cash; the receipts were explained as signed in a brokerage capacity, and no corroborative evidence of possession, flow of funds, or unexplained money was produced. Both additions were deleted.

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Issues: (i) Whether the addition towards alleged unaccounted cash from transfer of immovable property could be sustained for assessment years 2018-19 and 2019-20 on the basis of a loose sheet and without incriminating material relating to the relevant years. (ii) Whether the addition of Rs. 98,00,000 under section 69A could be sustained on the basis of seized digital documents and receipts without evidence showing that the assessee was the owner, beneficiary, or recipient of the alleged cash.

Issue (i): Whether the addition towards alleged unaccounted cash from transfer of immovable property could be sustained for assessment years 2018-19 and 2019-20 on the basis of a loose sheet and without incriminating material relating to the relevant years.

Analysis: The seized loose sheet did not record any sale consideration received by the assessee and was dated 04.03.2017, relating to a different year. The assessment additions for the two years under appeal were made by assuming on-money only from the sale deeds and without any independent material linking the document to the relevant assessment years. In an unabated search assessment, additions cannot be made in the absence of incriminating material pertaining to the year under consideration.

Conclusion: The addition was not sustainable and was deleted in favour of the assessee.

Issue (ii): Whether the addition of Rs. 98,00,000 under section 69A could be sustained on the basis of seized digital documents and receipts without evidence showing that the assessee was the owner, beneficiary, or recipient of the alleged cash.

Analysis: The agreement to sell identified other persons as the contracting parties, while the assessee's name did not appear as buyer, seller, or beneficiary. The receipts bearing the assessee's signatures were explained as having been signed only on behalf of the seller in the course of brokerage activity, and no contrary material was brought to show ownership, possession, beneficial interest, flow of funds, or receipt of cash by the assessee. The addition rested on presumption rather than corroborated evidence and there was no incriminating material for the relevant year.

Conclusion: The addition was not sustainable and was deleted in favour of the assessee.

Final Conclusion: Both additions were deleted, and both appeals were allowed.

Ratio Decidendi: In an unabated search assessment, no addition can be made under section 153A without incriminating material relating to the relevant assessment year, and an addition under section 69A cannot rest on presumption alone without evidence linking the assessee to the alleged unexplained money.

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