CIT(A) Rejects AO's Disallowance of Section 80IAB; Revenue Needs to Prove Incriminating Documents Exist in Section 153A Case.

Assessment u/s 153A - Disallowance of section 80IAB - CIT(A) has already rejected the contention of the AO in remand proceeding which were based on the appraisal report. Merely, if it is mentioned in the appraisal report that certain documents are found during the course of the search, which are incriminating in nature, it cannot be presumed that such material was found. The onus is on the Revenue to substantiate their claim with the help of producing relevant incriminating material either before the Ld. CIT(A) or before the Tribunal. - AT .....

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