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Additions u/s 153A solely based on a sketchy statement of an accountant u/s 132(4), which in turn is based on a confessional statement of a director in a previous search, are impermissible. No incriminating material was discovered during the search in the assessee's case. The statement of the director in the previous search cannot be regarded as incriminating material found in the course of the assessee's search. Mere confessional statements without other material are unsustainable in law. In the absence of incriminating material found during the search, the legal foundation for making additions u/s 153A in unabated assessments does not exist, as per the Supreme Court's judgment in Pr. CIT vs. Abhisar Builwell Pvt. Ltd. and the Delhi High Court's ruling in Pavitra Realcon Pvt. Ltd. and Anand Kumar Jain (HUF). Additions made u/s 153A are not permissible. The assessee's appeal is allowed.
Additions u/s 153A solely based on a sketchy statement of an accountant u/s 132(4), which in turn is based on a confessional statement of a director in a previous search, are impermissible. No incriminating material was discovered during the search in the assessee's case. The statement of the director in the previous search cannot be regarded as incriminating material found in the course of the assessee's search. Mere confessional statements without other material are unsustainable in law. In the absence of incriminating material found during the search, the legal foundation for making additions u/s 153A in unabated assessments does not exist, as per the Supreme Court's judgment in Pr. CIT vs. Abhisar Builwell Pvt. Ltd. and the Delhi High Court's ruling in Pavitra Realcon Pvt. Ltd. and Anand Kumar Jain (HUF). Additions made u/s 153A are not permissible. The assessee's appeal is allowed.
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