Section 153A Addition Valid Only if Based on Material Seized during search: ITAT Kolkata

Late Ghanshyam Das Agarwal Vs DCIT (ITAT Kolkata) ITAT Kolkata held that additions u/s. 153A of the Income Tax Act could only be made on the basis of seized material found during the course of search. Thus, making additions in regular assessment without any incriminating material relating to said addition not justified. Facts- Shri Ghanshyam Das Agarwal (appellant) was an individual running export business under the name and style of M/s. Bharat Export. There is one another business entity of the group called M/s. Navbharat Exports Pvt. Ltd. which is a company owned by Shri Uttam Kumar Agarwal...