2025 (2) TMI 1821

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....HRI INTURI RAMA RAO, ACCOUNTANT MEMBER For the Appellant: None For the Respondent: Smt. Leena Lal, Senior AR ORDER These appeals filed by the assessee are directed against different orders of the Commissioner of Income-tax (Appeals)-3, Kochi ["CIT(A)" for short] dated 7th May, 2024 for the assessment years 2006- 2007 to 2011-2012. 2. Since identical facts and issues are involved in ....

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....ssued u/s. 142(1) of the Act. In the above circumstances, the Assessing Officer (Assessing Officer) was constrained to complete the assessment at a total income of Rs. 8,44,795. While doing so, the AO made following additions / disallowances:- (i) Addition of disallowed unsecured loan Rs. 8,000 (ii) Addition of non-admitted income from Sahara Cable Rs. 2,09,717 (iii) Additi....

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....ontention of the assessee, the CIT(A) confirmed the addition made by the AO by holding that the addition is wholly based on the incriminating material found and seized. The CIT(A) further held by placing reliance on the judgment of the Hon'ble jurisdictional High Court in the case of CIT v. Hotel Meriya (2014) 362 ITR 664 (Ker.) that the AO is empowered to estimate the income of the assessee even ....

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....riminating material found and unearthed during the course of search and seizure operation or not. There is no quarrel as to the proposition of law that the addition u/s. 153A can only made on the basis of incriminating material found and unearthed during the course of search and seizure operation, as held by the Hon'ble Supreme Court in the case of Pr.CIT v. Abhisar Buildwell P.Ltd. (supra). In th....