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Section 153A, not section 147, governed reassessment because the additions were stated to arise from search material; the AO's assumption of jurisdiction under section 147 for AY 2011-12 was therefore invalid and the reassessment was quashed. For AY 2012-13 and AYs 2014-15 to 2018-19, additions based on alleged bogus capital gains, commission and cash loans were deleted because section 153A permits additions only on incriminating material found in the assessee's own search; third-party search material, even if confronted to the assessee, does not satisfy that requirement and would instead implicate section 153C. Notional interest additions were also deleted as derivative and unsupported by any real accrual or receipt.
Section 153A, not section 147, governed reassessment because the additions were stated to arise from search material; the AO's assumption of jurisdiction under section 147 for AY 2011-12 was therefore invalid and the reassessment was quashed. For AY 2012-13 and AYs 2014-15 to 2018-19, additions based on alleged bogus capital gains, commission and cash loans were deleted because section 153A permits additions only on incriminating material found in the assessee's own search; third-party search material, even if confronted to the assessee, does not satisfy that requirement and would instead implicate section 153C. Notional interest additions were also deleted as derivative and unsupported by any real accrual or receipt.
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