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2021 (2) TMI 667 - AT - Income TaxAssessment u/s 153A - Addition u/s 68 - third parties on whose statements the addition was made and sustained by the authorities - HELD THAT:- We find that a search & seizure operation was carried out on the group of assessees on 23/08/2016 and in the earlier appeals which were decided by the Tribunal [2020 (12) TMI 1064 - ITAT LUCKNOW] the Tribunal had made a finding of fact that in assessment year 2013-14, the additions could not have been made as additions were not made on the basis of material found during the course of search and the assessments in those years had already stood completed. As already held in our order dated 16/12/2020 in the case of the present assessees itself in other assessment years that additions were not made on the basis of any incriminating material as the Assessing Officer, while making the additions, had not relied on any seized material and had relied on the document marked as BK-2 which was seized by the search party from some other group and there the search took place almost one year before the date of search on the present assessee- Decided in favour of assessee.
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