Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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In search assessments under section 153A, additions cannot be made for completed or unabated assessment years unless incriminating material is found during the search. The High Court noted that this principle applies equally whether the earlier assessment was processed under section 143(1) or completed under section 143(3). As the Revenue did not dispute the absence of incriminating material and the Tribunal had deleted the additions on that basis, the Court found no error in the order and rejected the appeals.
In search assessments under section 153A, additions cannot be made for completed or unabated assessment years unless incriminating material is found during the search. The High Court noted that this principle applies equally whether the earlier assessment was processed under section 143(1) or completed under section 143(3). As the Revenue did not dispute the absence of incriminating material and the Tribunal had deleted the additions on that basis, the Court found no error in the order and rejected the appeals.
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