Addition based on documents found at separate search at another person under 153A unsustainable

ACIT Vs Atul Kumar Gupta (ITAT Delhi)

ITAT Delhi held that addition is made on the basis of documents found from the separate search at another person. Accordingly, assessment should have been done under section 153C of the Income Tax Act and not under section 153A of the Income Tax Act.

Facts- AO noted that during the course of search and post-search, it is found that assessee and Shri Rajiv Gupta are co-directors in many companies. In many of these companies, there were

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