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Pr. Commissioner Of Income Tax Central 3 vs Abhisar Buildwell P. Ltd. on 24 April, 2023

In this case also since there was no seized incriminating material found during the course of search , the AO has no jurisdiction to make the addition and therefore the Ld. CIT(A) rightly deleted the addition by following the decision of Hon'ble Apex Court in the case of Abhiser Buildwell Pvt. Ltd. (supra). Further, we also note that AY 2013-14 and 2014-15 were reopened beyond six years but before tenth year from the date of search in consonance with the 4th proviso to section 153A of the Act. We note that the jurisdiction has been exercised by the AO for these two assessment years without the necessary pre- conditions having been met namely. First, there was no incriminating material found during the course of search and second income represented in the form of asset which has escaped assessment should be Rs. 50,00,000/- or more. But, as a matter of fact, during search no such discovery of undisclosed assets was made by the search team. Keeping in view these facts and circumstances, we are inclined to hold that the Ld. CIT(A) has passed a very detailed, reasoned and speaking order which do not require any interference at our end. Accordingly, we dismiss the appeals of the revenue by upholding the orders of the Ld. CIT(A). The appeals for A.Y. 2013-14 & 2014-15 are dismissed on the ground of AO not having met the mandate of 4th proviso to section 153A and A.Y. 2015-16 to 2019-20 which were unabated assessments on the date of 15 I.T.(S.S).A. Nos.23 & 24/Kol/2024 IT(SS)A Nos. 32 to 36/Kol/2024 IT(S.S)A No. 64/Kol/2024 Assessment Years: 2013-14 to 2019-20 Girhar Tracom Pvt. Ltd.
Supreme Court of India Cites 23 - Cited by 85 - M R Shah - Full Document

Commissioner Of Income-Tax vs Sri Ramdas Motor Transport Ltd. on 23 August, 2001

In CIT v. Shri Ramdas Motor Transport [1999] 238 ITR 177/102 Taxman 300, a Division Bench of Andhra Pradesh High Court, reading the provision of Section 132(4) of the Act in the context of discovering undisclosed income, explained that in cases where no unaccounted documents or incriminating material is found, the powers under Section 132(4) of the Act cannot be invoked. The relevant passage from the aforesaid judgment is quoted below:--
Supreme Court of India Cites 2 - Cited by 59 - Full Document
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