https://www.taxtmi.com/caselaws?id=784105 In post-search assessments, the Tribunal held that, absent any incriminating material seized in the s.132 search, a mere statement recorded u/s 132(4) is not itself "incriminating material"; therefore enhancement of disclosed net profit to 11% based only on a later year's margin was conjectural, and the disclosed profit had to be accepted. On addition u/s 56(2)(vii)(b), since the AO made a non-speaking, summary addition on an erroneous DVO valuation despite higher actual consideration, the entire addition was directed to be deleted. The approvals purportedly granted u/s 148B/153D were found mechanical and vitiated (including non-disposal of the assessee's s.144A application), rendering the assessments void ab initio and liable to be annulled; independently, reassessment u/s 147/148 was held non est for want of "reason to believe" without incriminating material. en-us Thu, 11 Dec 2025 00:00:00 +0530 Mon, 22 Dec 2025 11:05:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784105 In post-search assessments, the Tribunal held that, absent any incriminating material seized in the s.132 search, a mere statement recorded u/s 132(4) is not itself "incriminating material"; therefore enhancement of disclosed net profit to 11% based only on a later year's margin was conjectural, and the disclosed profit had to be accepted. On addition u/s 56(2)(vii)(b), since the AO made a non-speaking, summary addition on an erroneous DVO valuation despite higher actual consideration, the entire addition was directed to be deleted. The approvals purportedly granted u/s 148B/153D were found mechanical and vitiated (including non-disposal of the assessee's s.144A application), rendering the assessments void ab initio and liable to be annulled; independently, reassessment u/s 147/148 was held non est for want of "reason to believe" without incriminating material. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784105