No additions solely on the basis of material found in possession of third party

RELEVANT PARAGRAPH

9. The perusal of the provisions (prior to the amendment) shows that additions could be made in respect of unaccounted income on the basis of evidence found as a result of search as well as such other material or information as were available with the Assessing Officer. Such provisions were considered by this Bench in the case of Parakh Foods Ltd. 64 ITD 396 wherein it was held that the additions could also be made by the Assessing Officer on

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