Unabated Assessment Protection: ITAT Deletes ₹6.70 Cr Share Addition; Third-Party Statement is Not Incriminating Material

DCIT Vs Jupiter International Limited (ITAT Kolkata) ₹6.70 Cr share application addition deleted as AY 2009-10 was an unabated year no incriminating material was found; third-party statement cannot be incriminating material u/s 153A A search u/s 132 was conducted on Jupiter Group on 24.03.2015. For AY 2009-10, the assessment had already been completed earlier & the time limit to issue notice u/s 143(2) had expired. Hence, AY 2009-10 was an “unabated year” on the date of search. In the original 153A/143(3) assessment, AO made an addition of ₹6,70,00,000 treating share application mo...