ITAT restricts section 153C additions, requires year-specific evidence, prevents double taxation on land investments

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....ITAT upheld CIT(A)'s decision restricting additions under section 153C search assessments. For unaccounted receipts, ITAT confirmed 20% profit margin on verifiable on-money receipts for AY 2015-16 only, deleting extrapolated additions for subsequent years lacking year-specific incriminating material. The tribunal emphasized that additions in non-abated assessments require incriminating documents relatable to specific assessment years. Regarding unaccounted land investment under section 69, ITAT deleted additions finding payments sourced from already-taxed unaccounted receipts, preventing double taxation. For alleged unaccounted cash expenditure under section 69C, ITAT upheld deletion as seized documents from third-party premises lacked nexus to assessee's business, with AO failing to establish connection through proper enquiry or corroboration.....