https://www.taxtmi.com/caselaws?id=763470 The ITAT Delhi held that additions made under section 153A for assessment years 2012-13 to 2014-15 were outside jurisdictional ambit as no incriminating material was found during the assessee's search. The alleged incriminating material consisted only of third-party statements recorded prior to search and materials found in other persons' searches. Following the SC judgment in Pr. CIT v. Abhisar Buildwell, additions in unabated assessments without incriminating material are impermissible. However, for abated assessment years 2015-16 onwards, the AO's power is not limited to incriminating material alone. The CIT(A)'s confirmation of additions was held unjustified where the AO had categorically accepted the veracity of the assessee's explanation regarding funds from preference share sales, supported by documentary evidence in the remand report. en-us Mon, 16 Dec 2024 00:00:00 +0530 Thu, 19 Dec 2024 15:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763470 The ITAT Delhi held that additions made under section 153A for assessment years 2012-13 to 2014-15 were outside jurisdictional ambit as no incriminating material was found during the assessee's search. The alleged incriminating material consisted only of third-party statements recorded prior to search and materials found in other persons' searches. Following the SC judgment in Pr. CIT v. Abhisar Buildwell, additions in unabated assessments without incriminating material are impermissible. However, for abated assessment years 2015-16 onwards, the AO's power is not limited to incriminating material alone. The CIT(A)'s confirmation of additions was held unjustified where the AO had categorically accepted the veracity of the assessee's explanation regarding funds from preference share sales, supported by documentary evidence in the remand report. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763470