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.

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