Absence of incriminating search material prevents deemed dividend addition u/s 2(22)(e) & 153A. Court upholds taxpayer's stance.

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....Addition u/s 153A was made for deemed dividend u/s 2(22)(e). However, following Abhisar Buildwell P. Ltd. [2023 (4) TMI 1056 - Supreme Court], the High Court held that the Assessing Officer would not be justified to assess income in the absence of incriminating material found during the search. As no such incriminating material was placed before the Court, the substantial questions of law were answered against the Revenue, affirming the Appellate Tribunal's order.....