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

07 on 31/10/2006 and the same was processed on 28/02/2007. Similarly for the Assessment Year 2007-08 was filed on 31/08/2007 and intimation was processed on 03/03/2009. For Assessment Year 2009-10, the return of income was filed on 18/09/2009. No notice u/s 143(2) was issued to the assessee for these three Assessment Years. No proceeding is pending before the Assessing Officer. There is no incriminating material found during the course of search. For these Assessment Years the entire addition have been based on bank accounts and books of accounts produced before Assessing Officer which are disclosed documents. The legal position in such cases is that no addition can be made in an assessment made u/s 153A r.w.s. 143(3) of the Act, which is not based on any incriminating material found during the course of search, in cases where the assessment is not abated. This proposition has been laid down in the case of Commissioner of Income Tax (Central-III) v. Kabul Chawla (2016) 380 ITR 573 (Del). Thus, assessments for the Assessment Year 2006-07, 2007-08 & 2009-10, wherein an addition is made u/s 153A r.w.s. 143(3) of the Act, is not based on any incriminating material found and seized during the course of search, is bad in law.
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