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    <title>2025 (7) TMI 1417 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that no additions could be made under section 153A as no incriminating material was found in possession of the assessee or its directors during the search. Additions based solely on statements of unrelated third parties, which were later retracted, were not sustainable. The tribunal clarified that the proper procedure under section 153C should have been followed after completing the unabated assessment year proceedings under section 153A, as per the Supreme Court&#039;s ruling in Calcutta Knitwears. Since the AO failed to adhere to this procedure, no action under section 153C could be taken for the year under appeal. Consequently, the additions were deleted.</description>
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      <title>2025 (7) TMI 1417 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=775349</link>
      <description>The ITAT Delhi held that no additions could be made under section 153A as no incriminating material was found in possession of the assessee or its directors during the search. Additions based solely on statements of unrelated third parties, which were later retracted, were not sustainable. The tribunal clarified that the proper procedure under section 153C should have been followed after completing the unabated assessment year proceedings under section 153A, as per the Supreme Court&#039;s ruling in Calcutta Knitwears. Since the AO failed to adhere to this procedure, no action under section 153C could be taken for the year under appeal. Consequently, the additions were deleted.</description>
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