2024 (4) TMI 885

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....IT-DR ORDER PER PRADIP KUMAR KEDIA - A.M.: The captioned appeal has been filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-IV, Kanpur ('CIT(A)' in short) dated 10.08.2022 arising from the assessment order dated 09.08.2021 passed by the Assessing Officer (AO) under Section 143(3) r.w. Section 153A of the Income Tax Act, 1961 (the Act) concerning AY 2014-15.....

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....o make additions / disallowances without making reference to any incriminating material found in the course of search. The AO has made additions of Rs. 4,216/- by invoking provisions of Section 2(22)(e) of the Act by taking cognizance of the facts emerging from books of account and records. No reference to any incriminating material has been made. 4. The ld. DR for the Revenue could not controv....

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....acts of the case and thus the scope of assessment under Section 153A is restricted to the incriminating material found in the course of search of the assessee owing to the fact that such assessment stood concluded / completed and thus do not get abated by operation of law. Guided by the principles laid down by the Hon'ble Apex Court in the case of Abhisar Buildwell (supra), we find force in the le....