PCIT v. Allied Perfumers Pvt. Ltd. (2021) 431 ITR 237 / 279 Taxman 185/ 198 DTR 59/ 323 CTR 365(Delhi) (HC)

S. 153A : Assessment – Search- No incriminating material found during search — Mere recording of satisfaction regarding undisclosed income not sufficient — Addition is held to be not valid [ S.132 ]

Dismissing the appeal of the revenue the Court held that  the Tribunal had found that in the entire assessment order, the Assessing Officer had not referred to any seized material or other material for the year under consideration having being found during the course of search in the case of the assessee, leave alone the question of any incriminating material for the year under appeal. Mere recording of satisfaction note was not sufficient. Deletion of addition is held to be valid .  ( AY. 2001-02, 2002-03)