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The ITAT quashed the additions made under section 153A, finding procedural and substantive illegalities. The tribunal held that incriminating documents were discovered during a search of a distinct taxable entity, not the assessee's premises. The assessment order was invalid due to improper invocation of section 292C and lack of opportunity for cross-examination. The tribunal emphasized that creating liability based on another entity's statements requires rigorous procedural safeguards. Consequently, the tribunal allowed the assessee's appeal, deleted the disputed additions, and rejected the revenue's grounds, finding no merit in sustaining the challenged assessment.
The ITAT quashed the additions made under section 153A, finding procedural and substantive illegalities. The tribunal held that incriminating documents were discovered during a search of a distinct taxable entity, not the assessee's premises. The assessment order was invalid due to improper invocation of section 292C and lack of opportunity for cross-examination. The tribunal emphasized that creating liability based on another entity's statements requires rigorous procedural safeguards. Consequently, the tribunal allowed the assessee's appeal, deleted the disputed additions, and rejected the revenue's grounds, finding no merit in sustaining the challenged assessment.
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