Section 153A: No Additions if no Incriminating Materials unearthed during search

PCIT Vs Gautam Bhalla (Delhi High Court)

Appellant states that the ITAT has erred in holding that the addition which was not based on incriminating material found during the search, could not be made the basis for an assessment order under section 153A of the Income Tax Act, 1961 without going into merits of the same.

High Court finds that both the CIT(A) and the ITAT have given concurrent findings of fact that no incriminating evidence/material had been found during the search. The ITAT a

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