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    <title>2018 (2) TMI 2064 - GUJARAT HIGH COURT</title>
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    <description>In a Section 153A assessment, additions and disallowances cannot be sustained unless they are based on incriminating material found during search. The Tribunal&#039;s view was supported by binding precedent that assessment under Section 153A does not permit independent additions on issues not founded on search material, including claims under Section 41(1) and alleged unaccounted purchase and sale. On that basis, the additions were held unsustainable in the absence of incriminating material, and the issue was answered against the Revenue.</description>
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      <description>In a Section 153A assessment, additions and disallowances cannot be sustained unless they are based on incriminating material found during search. The Tribunal&#039;s view was supported by binding precedent that assessment under Section 153A does not permit independent additions on issues not founded on search material, including claims under Section 41(1) and alleged unaccounted purchase and sale. On that basis, the additions were held unsustainable in the absence of incriminating material, and the issue was answered against the Revenue.</description>
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