https://www.taxtmi.com/caselaws?id=784477 In assessment under s.153A, the dominant issue was whether additions for alleged unreported commission could be sustained on the basis of seized material. The ITAT held that the seized documents did not belong to the assessee; consequently, any assessment or addition founded on such material lacked evidentiary basis and was unsustainable. The CIT(A)'s direction to apply a commission/net profit rate derived from the Settlement Commission's determination in a third-party group case was also held untenable because it rested on the same non-attributable seized documents. Accordingly, the additions/directions based on the seized material were set aside and the assessee's appeals on this ground were allowed. en-us Fri, 21 Nov 2025 00:00:00 +0530 Tue, 06 Jan 2026 08:47:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784477 In assessment under s.153A, the dominant issue was whether additions for alleged unreported commission could be sustained on the basis of seized material. The ITAT held that the seized documents did not belong to the assessee; consequently, any assessment or addition founded on such material lacked evidentiary basis and was unsustainable. The CIT(A)'s direction to apply a commission/net profit rate derived from the Settlement Commission's determination in a third-party group case was also held untenable because it rested on the same non-attributable seized documents. Accordingly, the additions/directions based on the seized material were set aside and the assessee's appeals on this ground were allowed. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784477