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    <title>2026 (7) TMI 514 - BOMBAY HIGH COURT</title>
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    <description>For a completed, unabated assessment, additions under section 153A of the Income-tax Act cannot be made unless supported by incriminating material found during the search; material already available with the Revenue does not justify disturbing finality. The article also states that an addition under section 69A fails unless the Revenue first proves that the assessee owned the money or asset in question. On the facts described, the foreign bank accounts stood in the names of foreign entities and the evidence did not establish ownership or control by the assessee, so the additions were held unsustainable and the Tribunal&#039;s deletion was upheld.</description>
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      <description>For a completed, unabated assessment, additions under section 153A of the Income-tax Act cannot be made unless supported by incriminating material found during the search; material already available with the Revenue does not justify disturbing finality. The article also states that an addition under section 69A fails unless the Revenue first proves that the assessee owned the money or asset in question. On the facts described, the foreign bank accounts stood in the names of foreign entities and the evidence did not establish ownership or control by the assessee, so the additions were held unsustainable and the Tribunal&#039;s deletion was upheld.</description>
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