https://www.taxtmi.com/caselaws?id=252782 The Tribunal held that the AO's addition based on ad hoc estimated disallowance of expenses without incriminating material found during the search was unjustified. The disallowance of expenses was deemed arbitrary, and the failure to provide an opportunity to be heard before making additions vitiated the assessment proceedings. The Tribunal emphasized that assessments under section 153A should be based solely on incriminating material found during the search and that the applicability of Rule 8D for disallowance of administrative expenses for the relevant assessment year was legally incorrect. Consequently, the Tribunal allowed the appeal and directed the AO to delete the addition. en-us Fri, 31 Oct 2014 00:00:00 +0530 Tue, 04 Nov 2014 06:05:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252782 The Tribunal held that the AO's addition based on ad hoc estimated disallowance of expenses without incriminating material found during the search was unjustified. The disallowance of expenses was deemed arbitrary, and the failure to provide an opportunity to be heard before making additions vitiated the assessment proceedings. The Tribunal emphasized that assessments under section 153A should be based solely on incriminating material found during the search and that the applicability of Rule 8D for disallowance of administrative expenses for the relevant assessment year was legally incorrect. Consequently, the Tribunal allowed the appeal and directed the AO to delete the addition. Case-Laws Income Tax Fri, 31 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252782