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Income Tax Case: Unsupported Additions Deleted Due to Lack of Incriminating Material in Construction Projects.

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Full Text of the Document

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....Assessment u/s 153C - Profit estimation on money received for new construction and redevelopment projects - extrapolation of income for the search period. The assessee contended that in the absence of any incriminating material seized from the premises, no addition could have been made u/s 153C for the assessment year under consideration. It was held that the Assessing Officer (AO) did not consider or hold the cash found as unexplained cash of the assessee, and it cannot be automatically subsumed in the addition related to 'on-money' without an express finding by the AO. The AO made an addition related to on-money based on material impounded during the survey and not under the search action. Therefore, no addition could have been made by th.........