Held that document found in the course of search, resumption cannot be extended to material found at the place of somebody else Assessment should have been under section 153C and not under section 153A. Held that CIT(A) has given finding that no incriminating material during the search additions made is deleted. (AY. 2011-12)
ACIT v. Atul Kumar Gupta (2023) 225 TTJ 431 (Delhi)(Trib)
S. 153A : Assessment-Search-Document found in the course of search-Presumption cannot be extended to material found at the place of somebody else-Assessment should have been under section 153C and not under section 153A-Undisclosed income-No incriminating material-Deletion of addition is affirmed. [ S. 132(4), 153C]