Assessment u/s 153C/153A - Addition u/s 68 - Seized ...
Incriminating material under IT Act Sections 153C and 153A must relate to specific assessment year for valid additions.
December 14, 2021
Case Laws Income Tax AT
Assessment u/s 153C/153A - Addition u/s 68 - Seized incriminating material has to pertain to the assessment year in question and have co-relation, document-wise, with the assessment year. This requirement u/s 153C is essential and becomes a jurisdictional fact. - No addition can be made where the assessment have not abated and were pending at the time of search, no addition can be made without any incriminating material. - AT
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