No addition/ disallowance u/s 153C without incriminating material found during third person search

DCIT Vs Khimji Karamshi Patel (ITAT Mumbai) ITAT Mumbai held that no additions or disallowances can be made u/s. 153C of the Income Tax Act in absence of any incriminating material found during the search on a third person. Facts- Assessee is an individual, filed his original ROI on 26.09.2008 declaring total income of Rs. Nil and the return was processed u/s. 143(1). Later on, information was received from the DDIT(Inv.) Unit-3(1) and 3(2), Mumbai vide letter dated 04.03.2015 that during search/survey action conducted on 09.10.2014 in the case of Kamdhenu/Green Valley Group, it was noticed th...