Dismissing the appeal of the revenue the Court held that ; where no incriminating evidence was found against assessee during course of search, additions cannot be made on basis of material collected after search. Court also held that , additions cannot be made on basis of statement of director of assessee company which was recorded under S. 131 much later after search. (AY. 2007-08)
PCIT v. Sunrise Finlease (P.) Ltd. (2018) 252 Taxman 407 / 171 DTR 237/ 305 CTR 421(Guj.)(HC)
S. 153A : Assessment – Search or requisition – When no incriminating material was found in the course of search, addition cannot be made on the basis of evidence collected after the search . No addition can be made on the basis of statement of director much later after the search [ S.131, 132 ]