Assessment U/s. 153A-No incriminating material- No Addition can be made

DCIT Vs Sopariwala Exports (ITAT Mumbai)

So far as the facts are concerned, it is uncontroverted position as noted by the learned Commissioner (Appeals) that no incriminating material was found in the search operations qua the additions and the additions were not based on any incriminating material. The original assessment under section 143(3) had already completed on 26-12-2006 whereas the search took place on 29-4-2008 which clearly reflect that no assessment was pend­ing on the date of search operations and no proceedings have abated

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