No section 69A Addition on mere surmises, conjectures & hypothesis & in the year in which no asset etc is found

DCIT Vs Shri Sanjay Singhal (ITAT Delhi) The undisputed fact is that the substantive as well as protective additions have been made u/s 69A r.w.s 115BBE of the Act. A bare perusal of the assessment order clearly shows that no money, bullion, jewellery or valuable article was found during search conducted on 07.04.2017 which is F.Y. 2017-18 relevant to A.Y 2018-19. Then, we fail to understand how the provisions of section 69A have been invoked for A.Y 2015-16 which is under consideration because u/s 69A of the Act, addition can be made in the year in which asset etc is found and since no such a...