The Revenue made additions under sections 68 and 69C on the basis of statements recorded during search in the cases of third parties alleging accommodation entries. The Tribunal held that no incriminating material was found during the search conducted in the assessee’s case and the assessments for the relevant years had already attained finality. In the absence of incriminating material, no addition could be made in proceedings under section 153A. The statements relied upon had also been retracted, and the deponents had no connection with the assessee. The additions were therefore deleted. The Revenue relied upon WhatsApp messages found in the mobile phone of a third person to make additions towards unexplained expenditure. The Tribunal held that the messages related to a subsequent assessment year and were recovered from a third person’s mobile phone. They did not constitute incriminating material against the assessee for the completed assessment years and could not form the basis of additions under section 153A. The Tribunal held that where material belonging to a person other than the searched person is found during search, the statutory procedure prescribed under section 153C must be followed by recording satisfaction and transferring the material to the jurisdictional Assessing Officer of such other person. As the mandatory procedure was not followed, the assessment could not be sustained under section 153A  (AY. 2013-14 to 2016-17).