In respect of completed/unabated assessments, no addition can be made by the AO in the absence of any incriminating material found during the course of a search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in the exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions therein. Followed CIT (Pr) v. Abhisar Buildwell P. Ltd (2023) 454 ITR 212 (SC) (AY. 2011-12)