AO not permitted to make additions in respect of already concluded assessments, where no adverse materials found during search

Brief of the Case Mumbai ITAT held In the case of Shri Uday C Tamhankar that the submission of assessee that the assessment years up to 2006-07 falls in the category of concluded assessments, i.e., assessments of those years were not pending on the date of initiation of search is a valid submission. Hence, in our view, the assessing officer could not have made these additions for AY 2004-05 to 2006-07 in the absence of any incriminating materials. Additions made by the AO, after accepting the additional disclosure of Rs.20.00 lakhs, would result in double assessment, since it is stated that th...