Dismissing the appeal of the Revenue the Court held that  the  Assessing Officer had merely relied upon the documents seized during the course of search for the financial years 2010-11 and 2011-12 even when the present batch of cases pertained to the assessment years 2005-06 to 2009-10. The Tribunal was right in concurring with the view of the Commissioner (Appeals) that no addition could be made on the basis of the documents found during the course of search pertaining to different assessment years. No substantial question of law arose from the order. Court also  held that  statement made during search has evidentiary value  but by itself cannot be basis for assessment. On facts the assessment completed before search and no incriminating material was found during search hence the deletion of addition is valid. Court also held that distinction  between scrutiny assessment under section 143() and summary assessment under section 143(1) is irrelevant for the purpose of section 153A.(AY.2005-06 to 2009-10)