Section 153A: No Additions Without Incriminating Material for Completed Assessments

PCIT Vs Satya Prakash Gupta (Delhi High Court) The case of PCIT vs Satya Prakash Gupta, as decided by the Delhi High Court, revolves around the applicability of Section 153A of the Income Tax Act, 1961, and the necessity of incriminating material for making additions to income during assessment. Here are the key points from the judgment: The assessee, engaged in a contract with a non-resident entity (CMF) for supply of currency paper to RBI, received commissions. A search under Sections 132 and 133A was conducted, and subsequent assessments were made under Section 153A for AYs 2012-13 to 2017-...