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2021 (7) TMI 730 - AT - Income TaxAssessment u/s 153A - incriminating material found in search or not? - HELD THAT:-Findings of learned CIT(A) clearly demonstrate that there was no incriminating material on the basis of which the Assessing Officer had made the additions. The existence of incriminating material for making additions u/s 153A is further strengthened from the decision of Hon'ble Supreme Court in the case of CIT vs. Sinhgad Technical Education Society [2017 (8) TMI 1298 - SUPREME COURT] where Hon'ble Supreme Court in a case u/s 153C has again highlighted the importance of existence of incriminating material for making the additions. The Hon'ble Supreme Court went on to hold that the Assessing Officer, while relying on the incriminating material, has to make reference in the satisfaction note regarding year-wise existence of incriminating material. Since there is an interplay between section 153A and section 153C, the findings of Hon'ble Supreme Court in a case u/s 153C are applicable for making additions u/s 153A also.
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