Incriminating material requirement: Section 153A assessments require material specific to the assessee, not unrelated third party statements.
Assessments following search operations must be grounded on incriminating material specifically linked to the assessee; material or statements derived from separate or third party search proceedings cannot, alone, serve as incriminating material against an unrelated assessee. Absent assesseespecific incriminating material, additions and disallowances in such assessments lack justification and cannot properly form the basis of adverse tax adjustments.