Revenue challenged deletion of additions made under 153A in absence of seized material. Relying on its earlier decision in assessee’s case the High Court held that no addition can be made for completed assessments without incriminating material.
PCIT v. Saroj Sudhir Kothari [2023] 154 taxmann.com 127 (Bom)(HC) Editorial : SLP dismissed, PCIT v. Saroj Sudhir Kothari [2023] 154 taxmann.com 128 / 455 ITR 379 (SC).
S. 153A : Search assessments-Completed assessments-Additions without incriminating material not sustainable. [S. 132, 260A]