https://www.taxtmi.com/caselaws?id=465782 In assessment under s.153A for non-abated years, the dominant issue was whether an addition could be sustained solely on additional income offered by the assessee in a settlement application (s.245C) when no incriminating material was found in search. The ITAT held that s.153A permits disturbance of completed assessments only to the extent of income evidenced by incriminating material seized during search, and a voluntary, ad hoc disclosure made to render a settlement petition maintainable or for "peace of mind" is not substantive evidence of undisclosed income. As the disclosure was the sole basis and the original return had been accepted without such addition, the addition lacked legal foundation and was deleted; the assessee's grounds were allowed. en-us Fri, 24 Jan 2025 00:00:00 +0530 Thu, 08 Jan 2026 21:13:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465782 In assessment under s.153A for non-abated years, the dominant issue was whether an addition could be sustained solely on additional income offered by the assessee in a settlement application (s.245C) when no incriminating material was found in search. The ITAT held that s.153A permits disturbance of completed assessments only to the extent of income evidenced by incriminating material seized during search, and a voluntary, ad hoc disclosure made to render a settlement petition maintainable or for "peace of mind" is not substantive evidence of undisclosed income. As the disclosure was the sole basis and the original return had been accepted without such addition, the addition lacked legal foundation and was deleted; the assessee's grounds were allowed. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465782