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No addition as undisclosed income can be made on the basis of documents which are dumb and incapable of any interpretation in proceedings u/s 132, 158BC read with Section 158BD
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अगर आप अपने आयकर आयकर छापे के विवाद को निपटाने के लिए सेटलमेंट में एप्लीकेशन लगा रहे हैं तो निम्न बातों का ध्यान रखें नहीं तो आपकी एप्लीकेशन रद्द की जा सकती है
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No incriminating material was found during search that would have resulted in any addition in income returned by assessee. It was also an uncontroverted fact that assessment consequent to return of income filed u/s 139 for AY 2006-07 was completed. Thus, on date of search, no assessment was pending which could have abated. It was a case of non-abated assessment. No addition could be made in respect of assessments which became final if no incriminating material was found during search.
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any addition u/s 153A can be made only on the basis of incriminating material found during course of search.No addition can be made on the basis of papers / information submitted during proceedings
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Since the assessee has shown more stock then physical stock found during search; therefore, no addition can be made on the basis of the undisclosed stock.
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Since no incriminating material was unearthed by AO during the course of search operation under section 132, therefore no addition could be made during the relevant assessment year under section 153A
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incriminating material found in survey
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document found during the course of search
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आयकर छापा