The ITAT observed that the date of handing over of the materials was not mentioned in the satisfaction note and, therefore, in the absence thereof the date of satisfaction note shall be reckoned as the date of handing over of the materials, and consequently, the time limit of calculating the six years has to be calculated from this date i.e. 02.02.2016 in the present. Therefore, in the present case, AY 2008-09 was held to be beyond the period of six AYs i.e. time barred. With respect to addition u/s 68 in the absence of any seized incriminating documents/materials in the assessment completed u/s 153C r.w.s. 153A, the ITAT held that in respect of completed or unabated assessment no addition can be made by the AO in the absence of any incriminating material having been found during the course of search u/s 132 or requisition u/s 132A. (AY 2008-09 and 2013-14)