Late TDS Interest Not Deductible Under Section 201(1A); Search-Based Additions Invalid Without Incriminating Evidence

ITAT ruled on multiple issues in a tax appeal. Interest paid on late TDS deposits under s.201(1A) was held non-deductible as it neither qualifies as business expenditure nor compensatory payment. Regarding additions in unabated assessment years during search proceedings, following SC precedent in Abhisar Buildwell, additions were deleted due to lack of incriminating material. Notice under s.153C was upheld valid as search warrant and panchnama were not issued in assessee's name. Addition under s.69C was deleted as CIT(A) found sufficient opening cash balance as of 01.04.2017 to justify transactions, and AO failed to prove actual cash payments versus mere projections. .....

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