Held that the loose sheets recovered in a search action carried out under section 132 of the Act in the case of Kasera  group, and relied upon by the Revenue, were brought by the search party with them. No incriminating material whatsoever was found during the course of search action in the case of the assessee. The alleged incriminating material found in the case of a past search action in the case of third party, i. e., Kasera  group was not acted upon and no proceedings under section 153C were initiated or contemplated. Thus, the Assessing Officer could not make such dead material the basis in the subsequent assessment proceedings carried out in the case of the assessee under section 153A to make additions, when the limitation to proceed under section 153C on the basis of the loose sheets or incriminating material had already expired in terms of the provisions of section 153B. Therefore, according to the provisions of section 132 read with the provisions of section 153B, the search party had exceeded its jurisdiction in recording statement of the assessee under section 132(4), and by bringing the documents from its record and thereby confronting the assessee in respect of the document during the recording of the statement would not infuse life in such dead documents.  That neither any assessment proceedings under section 153C of the Act were initiated nor pending on the date of search. No other assessment proceedings were initiated, or pending on the date of search. Therefore, no assessment stood abated on the date of the search. Since, no assessment stood abated, the assessment year under consideration would fall within the scope of unabated assessment year. Therefore, the Assessing Officer was not justified to make the additions in the absence of any incriminating material found during the course of the search.(AY. 2018-19, 2019-20)