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    <title>2025 (2) TMI 984 - ITAT DELHI</title>
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    <description>For a completed or unabated assessment, additions under section 153A cannot be sustained unless incriminating material is found during search. Where the assessment was already concluded on the date of search and the additions were made only from return particulars or material already available in assessment proceedings, the expansion of assessed income under section 153A was treated as impermissible. The additions were deleted for want of search-based incriminating material, while the Revenue&#039;s liberty to proceed under sections 147 and 148 in appropriate cases was noted.</description>
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      <description>For a completed or unabated assessment, additions under section 153A cannot be sustained unless incriminating material is found during search. Where the assessment was already concluded on the date of search and the additions were made only from return particulars or material already available in assessment proceedings, the expansion of assessed income under section 153A was treated as impermissible. The additions were deleted for want of search-based incriminating material, while the Revenue&#039;s liberty to proceed under sections 147 and 148 in appropriate cases was noted.</description>
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