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    <title>2025 (1) TMI 563 - ITAT DELHI</title>
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    <description>ITAT Delhi held that additions under section 153A cannot be made without incriminating material found during search operations. The tribunal found that the assessments were completed cases where no seized material formed the basis for additions. Revenue admitted additions were made without incriminating material from search. CIT(A)&#039;s well-reasoned orders were upheld, supported by SC precedent in PCIT vs. Abhisar Buildwell Pvt. Ltd., which established that section 153A assessments require incriminating material from search. Decision favored assessee.</description>
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    <pubDate>Wed, 08 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 563 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=764501</link>
      <description>ITAT Delhi held that additions under section 153A cannot be made without incriminating material found during search operations. The tribunal found that the assessments were completed cases where no seized material formed the basis for additions. Revenue admitted additions were made without incriminating material from search. CIT(A)&#039;s well-reasoned orders were upheld, supported by SC precedent in PCIT vs. Abhisar Buildwell Pvt. Ltd., which established that section 153A assessments require incriminating material from search. Decision favored assessee.</description>
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