Addition in Section 153A Assessment cannot sustain if no ‘Incriminating Material’ found during Search

Assessment under section 153A can be made on the basis of incriminating material which in the context of relevant provisions means books of account and other documents found in the course of search but not produced in the course of original assessment and undisclosed income or property disclosed during the course of search.  Relevant Extract of the Judgment 7. Heard rival submissions and perused the material available on record. The dispute raised is regarding legal validity of additions made by AO under section 153A proceedings of the Act. Under the provisions of section 153A, in all cases,...