https://www.taxtmi.com/caselaws?id=769529 ITAT Delhi held that AO cannot make additions under Section 153A assessment based solely on third-party statements recorded during search operations. The tribunal found that a pen drive containing trial balance showing unsecured loan of Rs. 30 lacs was not incriminating material as it reflected regular books of accounts. AO improperly relied on statements of directors from another searched entity declaring their company as shell company to conclude the loan was bogus. The tribunal ruled that for materials relating to persons other than those searched, proper procedure under Section 153C must be followed after recording satisfaction. Addition based exclusively on third-party statements was deleted and assessee's appeal was allowed. en-us Wed, 23 Apr 2025 00:00:00 +0530 Sat, 26 Apr 2025 08:30:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769529 ITAT Delhi held that AO cannot make additions under Section 153A assessment based solely on third-party statements recorded during search operations. The tribunal found that a pen drive containing trial balance showing unsecured loan of Rs. 30 lacs was not incriminating material as it reflected regular books of accounts. AO improperly relied on statements of directors from another searched entity declaring their company as shell company to conclude the loan was bogus. The tribunal ruled that for materials relating to persons other than those searched, proper procedure under Section 153C must be followed after recording satisfaction. Addition based exclusively on third-party statements was deleted and assessee's appeal was allowed. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769529