A search action was conducted, and assessment proceedings were initiated under section 153A against assessee involving two transactions. Assessing Officer made an addition of 100 per cent in respect of one transaction and 20 per cent in respect of other transaction. Commissioner (Appeals) reduced said additions to 15 per cent in relation to both transactions. Tribunal, upon appeal by the assessee, quashed additions, holding that no incriminating material was found during search and, therefore, assumption of jurisdiction under section 153A itself was invalid. On appeal, the Court held that since the Tribunal’s decision was based on the decision of the jurisdictional High Court in CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd. [2015] 232 Taxman 270/374 ITR 645 (Bom)(HC)  as approved by Supreme Court in Pr. CIT v. Abhisar Buildwell (P.) Ltd [2023] 293 Taxman 141/454 ITR 212 (SC), no substantial question of law arose from the Tribunal’s order