Ultimate Builders v. ACIT (2019) 183 DTR 179 / 202 TTJ 91 / 74 ITR 566 (Indore)(Trib.)

S. 153A : Assessment-Search or requisition-Addition made towards undisclosed income on the basis of statement made after the period of search-having no nexus with the incriminating material found during search–not sustainable. [S. 132(4)]

Allowing the Assessee’s appeal, the Tribunal held that statement made after the period of search cannot be considered as the statement given under S. 132(4) of the Act. Further, it was held that additions made merely on the basis of statement given without correlating the addition with the incriminating seized material cannot be sustained. (AY. 2014-15)