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The ITAT rejected the appellant's contention that approval under section 153D was granted mechanically, finding sufficient application of mind by the Approving Authority. While affirming that additions for unabated assessment years must be based on incriminating material found during search, the Tribunal remanded the matter to CIT(A) to allow the appellant opportunity to present documentary evidence. The CIT(A) was directed to delete additions that appellant could demonstrate were not based on incriminating search material. The Tribunal rejected appellant's argument that no additions could be made regarding items in books of accounts after rejection under section 145(3), noting that additions were based on both books of accounts and incriminating search material.
The ITAT rejected the appellant's contention that approval under section 153D was granted mechanically, finding sufficient application of mind by the Approving Authority. While affirming that additions for unabated assessment years must be based on incriminating material found during search, the Tribunal remanded the matter to CIT(A) to allow the appellant opportunity to present documentary evidence. The CIT(A) was directed to delete additions that appellant could demonstrate were not based on incriminating search material. The Tribunal rejected appellant's argument that no additions could be made regarding items in books of accounts after rejection under section 145(3), noting that additions were based on both books of accounts and incriminating search material.
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