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Search assessment and multiplex lease receipts: incriminating material limits additions, but commercial exploitation supported business income treatment.
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In completed assessments under section 153A, additions can be made only on the basis of incriminating material having a live nexus with undisclosed income; the seized loose sheet and sub-lease agreement did not meet that test for the unabated years, so the additions for A.Ys. 2013-14 to 2016-17 were deleted. For A.Y. 2017-18, the year was abated, and for A.Y. 2018-19, assessed as the search year, the absence of incriminating material did not bar a fresh assessment, so that jurisdictional objection failed. On merits, receipts from the multiplex lease were treated as business income because the asset was commercially exploited under a structured arrangement, and the receipts had consistently been disclosed on that basis.
In completed assessments under section 153A, additions can be made only on the basis of incriminating material having a live nexus with undisclosed income; the seized loose sheet and sub-lease agreement did not meet that test for the unabated years, so the additions for A.Ys. 2013-14 to 2016-17 were deleted. For A.Y. 2017-18, the year was abated, and for A.Y. 2018-19, assessed as the search year, the absence of incriminating material did not bar a fresh assessment, so that jurisdictional objection failed. On merits, receipts from the multiplex lease were treated as business income because the asset was commercially exploited under a structured arrangement, and the receipts had consistently been disclosed on that basis.
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