Section 153A Assessment Based Solely on Documents Seized from Third Party Invalid: ITAT Delhi

Kiran Mahana Vs DCIT (ITAT Delhi) No Incriminating Material Found on Assessee—153A Assessment Based Solely on Documents Seized from Third Party Invalid; Proceedings Should Have Been u/s 153C—Assessment Quashed The Assessee originally filed return for AY 2014-15 declaring income of ₹2,48,330, later revised to ₹8,92,310 in response to notice u/s 153A. Search operations on the LARA Group led to the issue of a warrant only for the Assessee’s lockers, from which no incriminating documents or valuables were found or seized. However, the AO made an addition of ₹21,80,000 u/s 69B alleging ...