Bangalore ITAT Bars Additions in Unabated 153A Cases Without Incriminating Material

Sarvana Prasad Vs DCIT (ITAT Bangalore) Bangalore ITAT : No Addition in Unabated 153A Assessments Without True ‘Incriminating Material’ – Mere Change of Head of Income Not Permissible The Bangalore ITAT held that in respect of completed/unabated assessments, additions under section 153A can be made only on the basis of real incriminating material unearthed during search. The Tribunal observed that a mere change of opinion regarding the head of income or legal characterization of already disclosed transactions does not amount to incriminating material. Accordingly, additions made by t...