https://www.taxtmi.com/caselaws?id=794628 Completed, unabated assessments under section 153A may be disturbed only on the basis of incriminating material found during the search; material already available to the Revenue, such as a Base Note, cannot support additions. Consequently, additions founded solely on such pre-existing material are unsustainable. For an addition under section 69A, the Revenue must first establish that the assessee owned or controlled the unexplained money or asset. Foreign bank accounts held in the names of foreign entities, without evidence linking ownership or control to the assessee, do not satisfy that burden. The Tribunal's deletion of both additions was upheld and the Revenue's challenge failed. en-us Wed, 01 Jul 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794628 Completed, unabated assessments under section 153A may be disturbed only on the basis of incriminating material found during the search; material already available to the Revenue, such as a Base Note, cannot support additions. Consequently, additions founded solely on such pre-existing material are unsustainable. For an addition under section 69A, the Revenue must first establish that the assessee owned or controlled the unexplained money or asset. Foreign bank accounts held in the names of foreign entities, without evidence linking ownership or control to the assessee, do not satisfy that burden. The Tribunal's deletion of both additions was upheld and the Revenue's challenge failed. Case-Laws Income Tax Wed, 01 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794628