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    <title>2026 (5) TMI 1625 - ITAT DELHI</title>
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    <description>In an unabated assessment under section 153A, additions cannot be sustained unless they are based on incriminating material found during search. Here, the assessment year was treated as unabated because no assessment was pending on the date of search, and the addition rested on examination of the source of cash deposits in bank accounts of alleged paper companies, not on material discovered in the search. On that basis, the addition was held unsustainable under section 153A, and the matter was decided in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792423</link>
      <description>In an unabated assessment under section 153A, additions cannot be sustained unless they are based on incriminating material found during search. Here, the assessment year was treated as unabated because no assessment was pending on the date of search, and the addition rested on examination of the source of cash deposits in bank accounts of alleged paper companies, not on material discovered in the search. On that basis, the addition was held unsustainable under section 153A, and the matter was decided in favour of the assessee.</description>
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