It was held that the seized material contained notings in respect to certain unaccounted sales. The assessment order did not bring on record any such seized material which showed sales outside the books corresponding to each and every sale. Since section 153A of the Income-tax Act, 1961 can be invoked only with respect to the incriminating material found during the course of the search, and extrapolation without any incriminating material would be contrary to the spirit of the section. Hence, the Commissioner (Appeals) was justified in confining the addition to the income that arose from unaccounted sales recorded in the seized documents and dismissing the extrapolation made by the Assessing Officer. (AY. 2008-09, 2009-10)