https://www.taxtmi.com/caselaws?id=416610 In an unabated assessment under section 153A, an addition cannot be sustained when it is based only on a base note or external information and not on incriminating material found during the search. The text states that the disputed addition failed this jurisdictional test because no search material from the assessee's premises supported it, and the addition was therefore held unsustainable. It further states that a penalty under section 271(1)(c) founded solely on that deleted addition cannot survive once the underlying assessment addition falls away, so the penalty was directed to be deleted. en-us Thu, 25 Nov 2021 00:00:00 +0530 Mon, 03 Jan 2022 08:26:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416610 In an unabated assessment under section 153A, an addition cannot be sustained when it is based only on a base note or external information and not on incriminating material found during the search. The text states that the disputed addition failed this jurisdictional test because no search material from the assessee's premises supported it, and the addition was therefore held unsustainable. It further states that a penalty under section 271(1)(c) founded solely on that deleted addition cannot survive once the underlying assessment addition falls away, so the penalty was directed to be deleted. Case-Laws Income Tax Thu, 25 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416610