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    <title>2022 (10) TMI 1316 - ITAT SURAT</title>
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    <description>In an unabated assessment under section 153A, additions under section 68 cannot be sustained unless supported by incriminating material found during the search. Where the assessment year had already attained finality, and the share capital and share premium addition was not linked to any seized document, statement, or other search evidence, the Revenue could not justify the adjustment. Because the issue had already been examined in the original assessment and no incriminating material was shown, the addition was deleted as unsustainable in law.</description>
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      <description>In an unabated assessment under section 153A, additions under section 68 cannot be sustained unless supported by incriminating material found during the search. Where the assessment year had already attained finality, and the share capital and share premium addition was not linked to any seized document, statement, or other search evidence, the Revenue could not justify the adjustment. Because the issue had already been examined in the original assessment and no incriminating material was shown, the addition was deleted as unsustainable in law.</description>
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