PCIT (Central) 2 v. Jay Ambey Aromatics (2023) 156 taxmann.com 691 / (2024) 296 Taxman 475 (SC)

S. 153A: Assessment-Search-Assessment prior to search-Order of High Court is affirmed-SLP of Revenue is dismissed.[Art. 136]

High Court held that where assessment of assessee had attained finality prior to date of search and no incriminating documents or materials had been found and seized at time of search, no addition could be made under section 153A as case of assessee was of non-abated assessment. The Hon’ble Supreme Court, keeping in view, its decision of Pr. CIT v. Abhisar Buildwell (P.) Ltd. [2023] 149 taxmann.com 399/293 held that no case for interference is made out. Hence, SLP was dismissed. (AY. 2010-11,  2011-12)