Pursuant to search under section 132, notices under section 153A were issued, and assessments were completed under section 153A read with section 143(3). Assessing Officer made additions/disallowances. Commissioner (Appeals) deleted the additions, holding that they were not based on incriminating material found during the search. Tribunal upheld said deletion. Court held that where no incriminating material was found during the search in relation to additions, no addition could be sustained under section 153A in respect of completed/unabated assessments. Order of the Tribunal affirmed. (AY. 2006-07 to 2009-10)
PCIT, Central v. Maneesh Pharmaceuticals Ltd. (2026) 310 Taxman 470 (Bom)(HC)
S. 153A : Assessment-Search-No incriminating material-Unabated assessment-Order of Tribunal deleting the addition is affirmed. [S. 143(1), 143(3), 260A]
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