Income Tax Act: Section 153C Assessment Requires Incriminating Evidence from Search, Not Just Presumptions of Liability Cessation.

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....Validity of Assessment u/s 153C - Addition on account of forfeited amount of customers. - Assuming that there is a substantial time gap between the date of advance received and date of cancellation of the bookings, this fact may raise a strong presumption on cessation of liability, but even this presumption cannot justify the assessment u/s 153C of the Act which has to be based upon incriminating material found at the time of search - AT....