The ITAT ruled that in cases of completed/unabated assessments, additions cannot be made without incriminating material found during search. The Tribunal followed the Supreme Court decision in Principal CIT v. Abhisar Buildwell (P) Ltd. which established that for completed assessments, additions can only be made if incriminating material related to that specific issue was found during search.

Section 69C could not be applied to purchases already recorded in regular books of account when the books were not rejected by tax authorities, payments were made from disclosed bank accounts and the source of expenditure was duly explained.(AY. 2014-15)