Without incriminating material, additions cannot be made to completed/unabated assessments

ACIT Vs Mansha Agencies Pvt Ltd (ITAT Mumbai)

In this case, the Income Tax Appellate Tribunal (ITAT) considered the issue of whether the Assessing Officer (AO) could make additions to assessments when no incriminating material was found during a search conducted under section 132 or requisition under section 132A. The key points are as follows:

Background: The assessment year in question was an unabated year, falling within the scope of section 153A of the Income Tax Act. No incriminating material had been discovered during the search conducted on the assessee.

Supreme Court Decision (Abhisar Buildwell Pvt. Ltd.): The Supreme Court clarified that:

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