Section 153C addition should be based on Incriminating Materials Found During Search

Ashok Kumar Tyagi Vs ACIT (ITAT Delhi) ITAT held that the addition of agricultural income as income from other sources was not based on any incriminating/seized material found as a result of search. Even, the disallowance of loss claimed against house property income is also not with reference to any seized material. It is a fact on record that on the date of search, the assessment proceedings relating to the impugned assessment years did not abet. Therefore, as per the ratio laid down by the Hon’ble Jurisdictional High Court in the case of CIT vs. Kabul Chawla (2016) 380 ITR 0573 (Del), in ...