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Bangalore ITAT Bars Additions in Unabated 153A Cases Without Incriminating Material
Case Law Details
- Case Name
- Sarvana Prasad Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Bangalore
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Sarvana Prasad Vs DCIT (ITAT Bangalore)
Bangalore ITAT : No Addition in Unabated 153A Assessments Without True ‘Incriminating Material’ – Mere Change of Head of Income Not Permissible
The Bangalore ITAT held that in respect of completed/unabated assessments, additions under section 153A can be made only on the basis of real incriminating material unearthed during search. The Tribunal observed that a mere change of opinion regarding the head of income or legal characterization of already disclosed transactions does not amount to incriminating material. Accordingly, additions made by t...
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