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Commissioner Of Income Tax (Central) ... vs Kabul Chawla on 29 March, 2016

After careful consideration of submissions and records produced before me, I am of the view that A.O. was not justified to treat the credit entries appearing in the bank account as unexplained cash credits on any ground. Since there were no pending assessments at the time of issuance of notice u/s 153A of the act, completed assessments could not be interfered with by the AO while making the assessment under Section 153A without any incriminating material unearthed during the course of search. Assessment cannot be arbitrary or made without any relevance or nexus with the seized material. Obviously an assessment has to be made under these circumstances only on the basis of seized material. Cash found during the search was properly explained in the hands of the company to which the cash belonged and there was no other incriminating documents found during search related to the bank entries, the addition made by the AO are to be deleted, in view of the judgments of Premier Car Sales Ltd. v. Director General of Income-tax, Investigation (North) [2013] 40 taxmann.com 19 (All); and CIT (CENTRAL)-III v. KABUL CHAWLA in ITA 707/2014 (Del).
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