https://www.taxtmi.com/caselaws?id=782190 ITAT held that for A.Y. 2017-18, which was a completed/unabated assessment on the date of search, no additions could be made under s.153A in the absence of incriminating material found during search u/s 132 or requisition u/s 132A. The excel sheet retrieved from the accountant's email, being merely an internal document whose entries were already recorded in the regular books and scrutinized u/s 143(3), was not treated as incriminating material or evidence of undisclosed income. Consequently, additions made u/s 69C and the CIT(A)'s direction to consider disallowance u/s 40A(3) were held to be beyond jurisdiction and unsustainable. The assessee's appeal was allowed and the additions deleted. en-us Fri, 25 Jul 2025 00:00:00 +0530 Mon, 24 Nov 2025 15:33:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782190 ITAT held that for A.Y. 2017-18, which was a completed/unabated assessment on the date of search, no additions could be made under s.153A in the absence of incriminating material found during search u/s 132 or requisition u/s 132A. The excel sheet retrieved from the accountant's email, being merely an internal document whose entries were already recorded in the regular books and scrutinized u/s 143(3), was not treated as incriminating material or evidence of undisclosed income. Consequently, additions made u/s 69C and the CIT(A)'s direction to consider disallowance u/s 40A(3) were held to be beyond jurisdiction and unsustainable. The assessee's appeal was allowed and the additions deleted. Case-Laws Income Tax Fri, 25 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782190