No addition in absence of incriminating material: Statement u/s 132(4) not enough

Global Tech Park Pvt. Ltd Vs DCIT (ITAT Bangalore)

Assessment not abated – Block assessments must be based on seized incriminating material

Search & seizure operations were conducted on 01.02.2018 u/s 132. Assessments were completed u/s 153A r.w.s. 143(3)/153D for AYs 2012–13 to 2017–18. The appeals involved disallowance of depreciation on luxury cars & additions u/s 69 based on alleged unexplained investments.

Contentions of   Asseessee before Tribunal were:

• Date of search was 1.2.2018 which was concluded on 29.3.2018. As on the date of s

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