Held that, the assessee has offered the cumulative amount of unaccounted capital to tax as undisclosed income in all the assessment years and the AO having duly accepted the same, he was not justified in making the impugned addition for one year only by adopting the figure of unaccounted assets as undisclosed income in the relevant assessment year in place of the unaccounted capital offered by the assessee in the return filed under S. 153A. (AY. 2013-14)
ACIT v. River Valley Flour Mills (P) Ltd. (2022) 220 TTJ 127/220 DTR 55 (Pat) (Trib) ACIT v. Chandana Kothari (Smt) & Ors. (2022) 215 TTJ 729 /211 DTR 149 (Nag) (Trib)
S. 153A : Assessment-Search or requisition-Search and seizure-Wrongly adopting the figure of unaccounted assets in place of the unaccounted capital offered by the assessee in the return of income-Deletion of addition was affirmed.