Section 153A Assessment: Addition without incriminating Seized Material is not sustainable

Dinesh Salecha Vs DCIT (ITAT Mumbai) It was expounded that in case of assessments which have attained finality no addition under section 153A can be done without seized incrementing material. We are aware that in these cases earlier assessments were not done u/s 143(3). In our considered opinion, the Hon’ble Jurisdictional High Court has never mentioned that it is only assessment which has been completed under section 143(3) that addition under section 153A cannot be done without reference to incriminating seized material. Hon’ble Jurisdictional High Court has clearly mentioned tha...