PCIT v. Abhisar Buildwell Pvt. Ltd.

454 ITR 212Supreme Court of India2023#35 most cited

What is PCIT v. Abhisar Buildwell Pvt. Ltd. authority for?

In assessments under Sections 153A and 153C, the Assessing Officer's jurisdiction to make additions for completed or unabated assessments is limited to income based on incriminating material found during the search and seizure operation. No additions can be made for these assessment years in the absence of such material.

1,249

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2026.

Also referred to as

PCIT v. Abhisar Buildwell · Abhisar Buildwell SC · Section 153A assessment · Section 153C assessment · incriminating material requirement · completed assessments search · unabated assessments additions · AO jurisdiction search assessment · no additions without seized material · Section 132 search

Also reported as

154 Taxmann.com 45

Sections most often in play

Section 153ASection 143(3)Section 132Section 153CSection 147Section 148Section 143(2)Section 68

Issues it is cited on

section 158basection 113section 153a proceedingssection 158bdsection 153b(1)section 150block periodunexplained jewellerysearch assessmentsection 132asection 158bsection 153c(1)

Judgments citing PCIT v. Abhisar Buildwell Pvt. Ltd.

SHIMLA HILLS CONSTRUCTION,SHIMLA vs. DCIT, CENTRAL CIRCLE SHIMLA, SHIMLA

In the result, appeal is allowed

ITA 231/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh16 Mar 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 231/Chd/2025 िनधा"रण वष" / Assessment Year: 2013-14 Shimla Hills Construction, The Dcit, Village Kot, Po-Junga, Vs Central Circle, Tehsil & Distt. Shimla. Shimla. "ायी लेखा सं./Pan No: Absfs7322L अपीलाथ"/Appellant ""थ"/Respondent Assessee By : Shri Vishal Mohan, Sr. Advocate With Shri Besar Singh Verma, Advocate & Shri Aman Singhi, Ca Revenue By : Shri Abhishek Pal Garg, Cit Dr Date Of Hearing : 09.02.2026 Date Of Pronouncement : 16.03.2026

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Besar Singh Verma, Advocate &For Respondent: Shri Abhishek Pal Garg, CIT DR
Section 132(1)Section 139(1)Section 143(2)Section 143(3)Section 153A

…essment order has been passed u/s 153A but ld. AO has not referred any incriminating material in the assessment order, therefore, additions are not sustainable in view of latest judgement of the Hon'ble Supreme Court in the case of Abhisar Buildwell Pvt. Ltd. 454 ITR 212. 3. The brief facts of the case are that a search u/s 132(1) was carried out at the premises of the assessee on 19.11.2018. In order to give logical end to the proceedings, ld. AO has issued notice u/s 153A of the Act. The assessee has filed its return of income on 08.02.2020 declaring total income of Rs.5,40,970/- which is equivalent to the amou…

ABCI INFRASTRUCTURES PVT. LTD.,KOLKATA, WEST BENGAL vs. ACIT/DCIT, CENTRAL CIRCLE 1, GUWAHATI, GUWAHATI, ASSAM

In the result, both the appeals of the assessee are allowed

ITA 419/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

…ed under Section 153A of the Act, however, in order to buy peace of mind, the said disclosure was made. It is trite law as settled by the Hon'ble Supreme Court in the case of PCIT, Central-3 Vs Abhisar Buildwell (P) Ltd. (2023) 149 taxmann.com 399 (SC)/(2023) 454 ITR 212 (SC) wherein it has been held that in the case of unabated assessment, the Assessing Officer has no jurisdiction to make addition unless the search team has found incriminating material qua the proposed addition by the Assessing Officer. Therefore, even on this count, the penalty levied by the Assessing Officer is not sustainable in the eyes of l…

ABCI INFRASTRUCTURES PVT. LTD.,KOLKATA, WEST BENGAL vs. ACIT/DCIT, CENTRAL CIRCLE 1, GUWAHATI, GUWAHATI, ASSAM

In the result, both the appeals of the assessee are allowed

ITA 418/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

…ed under Section 153A of the Act, however, in order to buy peace of mind, the said disclosure was made. It is trite law as settled by the Hon'ble Supreme Court in the case of PCIT, Central-3 Vs Abhisar Buildwell (P) Ltd. (2023) 149 taxmann.com 399 (SC)/(2023) 454 ITR 212 (SC) wherein it has been held that in the case of unabated assessment, the Assessing Officer has no jurisdiction to make addition unless the search team has found incriminating material qua the proposed addition by the Assessing Officer. Therefore, even on this count, the penalty levied by the Assessing Officer is not sustainable in the eyes of l…

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. WHITELOTUS SOLAR PRIVATE LIMITED, HYDERABAD

In the result the appeal of the revenue is dismissed

ITA 2134/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Mar 2026AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Bipin C.N., C.I.TFor Respondent: Ms. Vinita Shah, C.A. (by Virtual)
Section 132Section 139(1)Section 143(3)Section 153ASection 68

…आयकर अपील"य अ"धकरण, ‘सी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी एबी ट" वक", "या"यक सद"य एवं "ी एस. आर. रघुनाथा, लेखा सद"य के सम$ BEFORE SHRI ABY T VARKEY, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:2134/Chny/2025 "नधा%रण वष% / Assessment Year: 2015-16 DCIT, Whitelotus Solar Private Limited, Central Circle -1(2), vs. (Studio-N), SY No.70, Narne Nagar, Chennai. Beside Lanco Hills, Manikonda, Hyderabad – 500 089. Telangana. [PAN:AABCW-4598-D] (अपीलाथ'/Appellant) (()यथ'/Respondent) अपीलाथ' क+ ओर से/Appellant by : Shri. Bipin C.N., C.I.T.…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1324/DEL/2025[2023-24]Status: DisposedITAT Delhi11 Mar 2026AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1323/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1322/DEL/2025[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue

ITA 1321/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Tarun Chanana, Adv
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon'ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search on 12-12-2022. Hence Assessment Year 2016-17 falls in the category of completed assessment as on the…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1320/DEL/2025[2019-20]Status: DisposedITAT Delhi11 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1319/DEL/2025[2018-19]Status: DisposedITAT Delhi11 Mar 2026AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1318/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MALHOTRA CABLES PVT LTD, DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1317/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

MALHOTRA CABLES PRIVATE LIMITED,NEW DELHI vs. DCIT, CENTRA CIRCLE - 7, NEW DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1108/DEL/2025[2019-20]Status: DisposedITAT Delhi11 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

MALHOTRA CABLES PRIVATE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE -7, NEW DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1107/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

MALHOTRA CABLES PRIVATE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE -7, NEW DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1102/DEL/2025[2023-24]Status: DisposedITAT Delhi11 Mar 2026AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

MALHOTRA CABLES PRIVATE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE - 7, NEW DELHI

In the result, all the appeals of the assessee as well as the revenue are partly allowed

ITA 1097/DEL/2025[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Smt Kranti, CIT (DR)
Section 143(3)Section 148Section 149(1)(b)

…ncriminating material found during the course of search which constitutes income and which is represented in the form of an asset, expenditure etc. Accordingly, the ratio decidendi of Hon’ble Supreme Court in the case of Abhishar Buildwell Pvt Ltd reported in 454 ITR 212(SC) would be applicable even for 147 assessments framed consequent to search where 3 years had elapsed from the end of the ITA Nos. 1317 to 1324/Del/2025 ITA Nos. 1108, 1107, 1097 and 1102/Del/2025 Malhotra Cables Pvt. Ltd relevant assessment year. Admittedly, there was no proceeding pending for Assessment Year 2016-17 as on the date of search o…

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

ITA 2577/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Mar 2026AY 2018-19

Bench: This Tribunal.

Section 132Section 142Section 142(1)Section 143(2)Section 153A

…ating material seized from the premises of the assessee herein. 31. The Ld.AR accordingly placed reliance upon the decision of the Hon'ble Supreme Court in the case of Principal Commissioner of Income-tax, Central-3 v. Abhisar Buildwell (P.) Ltd, reported in 454 ITR 212, wherein the Hon'ble Supreme Court had held that in respect of completed assessments/unabated assessments, no addition could be made by AO in absence of any incriminating material found during course of search u/s.132 of the Act. 32. The Ld.AR argued that the Tally in hard disk seized vide Annexure No.ANN/VP/ABREPL/ED/S, containing the Tally acc…

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

ITA 2576/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

…ating material seized from the premises of the assessee herein. 29. The Ld.AR accordingly placed reliance upon the decision of the Hon’ble Supreme Court in the case of Principal Commissioner of Income-tax, Central-3 v. Abhisar Buildwell (P.) Ltd, reported in 454 ITR 212, wherein the Hon’ble Supreme Court had held that in respect of completed assessments/unabated assessments, no addition could be made by AO in absence of any incriminating material found during course of search u/s.132 of the Act. :-11-: ITA Nos: 2569, 2570, 2571, 2573 to 2577/Chny/2025 30. The Ld.AR argued that the Tally in hard disk seized vide…

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

ITA 2575/CHNY/2025[2015-16]Status: DisposedITAT Chennai09 Mar 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

…ating material seized from the premises of the assessee herein. 29. The Ld.AR accordingly placed reliance upon the decision of the Hon’ble Supreme Court in the case of Principal Commissioner of Income-tax, Central-3 v. Abhisar Buildwell (P.) Ltd, reported in 454 ITR 212, wherein the Hon’ble Supreme Court had held that in respect of completed assessments/unabated assessments, no addition could be made by AO in absence of any incriminating material found during course of search u/s.132 of the Act. :-11-: ITA Nos: 2569, 2570, 2571, 2573 to 2577/Chny/2025 30. The Ld.AR argued that the Tally in hard disk seized vide…

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

ITA 2574/CHNY/2025[2014-15]Status: DisposedITAT Chennai09 Mar 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 132Section 142Section 142(1)Section 143(2)Section 153A

…ating material seized from the premises of the assessee herein. 29. The Ld.AR accordingly placed reliance upon the decision of the Hon’ble Supreme Court in the case of Principal Commissioner of Income-tax, Central-3 v. Abhisar Buildwell (P.) Ltd, reported in 454 ITR 212, wherein the Hon’ble Supreme Court had held that in respect of completed assessments/unabated assessments, no addition could be made by AO in absence of any incriminating material found during course of search u/s.132 of the Act. :-11-: ITA Nos: 2569, 2570, 2571, 2573 to 2577/Chny/2025 30. The Ld.AR argued that the Tally in hard disk seized vide…

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