PCIT v. Kabul Chawla

126 DTR 130High Court2015#1715 most cited

What is PCIT v. Kabul Chawla authority for?

Additions cannot be made to an assessment already completed under Section 143(3) when proceedings are initiated under Section 153A, unless incriminating material specifically relating to that assessment year is discovered during the search operation.

67

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

PCIT v. Kabul Chawla · Kabul Chawla · Section 153A · Section 132 · Section 143(3) · incriminating material · completed assessment · search assessment · additions without incriminating material · Abhishar Buildwell

Also reported as

61 Taxmann.com 421

Sections most often in play

Section 153ASection 132Section 143(3)Section 147Section 148Section 263Section 131(1A)Section 69C

Issues it is cited on

place of effective managementsection 6(3)section 127(1)legal expensesddtpreponderance of probabilityprincipal officershell companyroyalty incomesection 112section 131(1a)colourable device

Judgments citing PCIT v. Kabul Chawla

VISHWAS SHASHIKANT CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

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

ITA 1399/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2015-16 Ashish Shashikant Choksi, Asst. CIT Central Circle-6(2), 68, Manglik Presidency Society, Room No. 450, 4th floor, Kautilya Vs. JVPD Scheme, 7th N S Road, Vile Bhavan, C-41 to C-43, G Block, Parle West, Bandra Kurla Complex, Bandra Mumbai-400049. East, Mumbai-400051. PAN NO. AEBPC 1539 B Appellant Respondent Assessment Year: 2015-16 Sidharth Abhay Choksi, Asst. CIT Central Circle-6(2), 24th floor, 2404, Indiabulls Sky, Room No. 450, 4t…

GAUTAM ASHOK CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

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

ITA 1398/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2015-16 Ashish Shashikant Choksi, Asst. CIT Central Circle-6(2), 68, Manglik Presidency Society, Room No. 450, 4th floor, Kautilya Vs. JVPD Scheme, 7th N S Road, Vile Bhavan, C-41 to C-43, G Block, Parle West, Bandra Kurla Complex, Bandra Mumbai-400049. East, Mumbai-400051. PAN NO. AEBPC 1539 B Appellant Respondent Assessment Year: 2015-16 Sidharth Abhay Choksi, Asst. CIT Central Circle-6(2), 24th floor, 2404, Indiabulls Sky, Room No. 450, 4t…

GAURAV ABHAY CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

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

ITA 1397/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2015-16 Ashish Shashikant Choksi, Asst. CIT Central Circle-6(2), 68, Manglik Presidency Society, Room No. 450, 4th floor, Kautilya Vs. JVPD Scheme, 7th N S Road, Vile Bhavan, C-41 to C-43, G Block, Parle West, Bandra Kurla Complex, Bandra Mumbai-400049. East, Mumbai-400051. PAN NO. AEBPC 1539 B Appellant Respondent Assessment Year: 2015-16 Sidharth Abhay Choksi, Asst. CIT Central Circle-6(2), 24th floor, 2404, Indiabulls Sky, Room No. 450, 4t…

VIKRAM SAJANLAL CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

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

ITA 1391/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16
Section 153A

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI BENCH “A” MUMBAI\nBEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER)\nAND\nSHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER)\nITA No. 1341/MUM/2025\n Assessment Year: 2015-16\nAshish Shashikant Choksi,\n68, Manglik Presidency Society,\nJVPD Scheme, 7th NS Road, Vile\nParle West,\nMumbai-400049.\nPAN NO. AEBPC 1539 B\nAppellant\nVs.\nAsst. CIT Central Circle-6(2),\nRoom No. 450, 4th floor, Kautilya\nBhavan, C-41 to C-43, G Block,\nBandra Kurla Complex, Bandra\nEast,\nMumbai-400051.\nRespondent\nITA No. 1344/MUM/2025\n Assessment Year: 2015-16\nSidharth Abhay Chok…

TANU GAUTAM CHOKSI ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI., MUMBAI

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

ITA 1345/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16
Section 153A

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI BENCH “A” MUMBAI\n\nBEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER)\nAND\nSHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER)\n\nITA No. 1341/MUM/2025\n Assessment Year: 2015-16\n\nAshish Shashikant Choksi,\n68, Manglik Presidency Society,\nJVPD Scheme, 7th NS Road, Vile\nParle West,\nMumbai-400049.\nPAN NO. AEBPC 1539 B\nAppellant\nVs.\nAsst. CIT Central Circle-6(2),\nRoom No. 450, 4th floor, Kautilya\nBhavan, C-41 to C-43, G Block,\nBandra Kurla Complex, Bandra\nEast,\nMumbai-400051.\nRespondent\n\nITA No. 1344/MUM/2025\n Assessment Year: 2015-16\n\nSidharth…

SIDHARTH ABHAY CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI., MUMBAI

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

ITA 1344/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16
Section 153A

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI BENCH “A” MUMBAI\nBEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER)\nAND\nSHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER)\nITA No. 1341/MUM/2025\n Assessment Year: 2015-16\nAshish Shashikant Choksi,\n68, Manglik Presidency Society,\nJVPD Scheme, 7th NS Road, Vile\nParle West,\nMumbai-400049.\nPAN NO. AEBPC 1539 B\nAppellant\nVs.\nAsst. CIT Central Circle-6(2),\nRoom No. 450, 4th floor, Kautilya\nBhavan, C-41 to C-43, G Block,\nBandra Kurla Complex, Bandra\nEast,\nMumbai-400051.\nRespondent\nITA No. 1344/MUM/2025\n Assessment Year: 2015-16\nSidharth Abhay Chok…

ASHISH SHASHIKANT CHOKSI,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI

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

ITA 1341/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2015-16 Ashish Shashikant Choksi, Asst. CIT Central Circle-6(2), 68, Manglik Presidency Society, Room No. 450, 4th floor, Kautilya Vs. JVPD Scheme, 7th N S Road, Vile Bhavan, C-41 to C-43, G Block, Parle West, Bandra Kurla Complex, Bandra Mumbai-400049. East, Mumbai-400051. PAN NO. AEBPC 1539 B Appellant Respondent Assessment Year: 2015-16 Sidharth Abhay Choksi, Asst. CIT Central Circle-6(2), 24th floor, 2404, Indiabulls Sky, Room No. 450, 4t…

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA Nos. 513 & 519 to 521/JP/2025 fu/kZkj.k o"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21 cuke Sunil Kumar Agarwal ACIT, Vs. 395, Narnoli Mansion, Outside Central Circle-2, Sanganeri Gate, Jaipur Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ABRPA9601M vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITSS No. 03/JP/2025 fu/kZkj.k…

SUPER CASSETTES INDUSTRIES PRIVATE LIMITED,DELHI vs. DCIT CENTRAL CIRCLE 3, DELHI

ITA 7/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

…erefore, expenses entries are only accommodation\nentries.\n8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16\nwere deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble\nDelhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421\nwhich was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar\nBuildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that\nassessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much\nbefore the date of search i.e. 28.11.2018 and therefore, the said assessment is\ncompleted assessment. Since no incr…

SUPER CASSETTES INDUSTRIES PRIVATE LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-3, DELHI

ITA 51/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, NEW DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

ITA 326/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 281/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 280/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…d therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 279/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…d therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, NEW DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

ITA 273/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…d therefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrimina…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 3, DELHI, DELHI vs. SUPER CASSETTES INDUSTRIES PVT. LTD., DELHI

ITA 272/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

SUPER CASSETTES INDUSTRIES PRIVATE LIMITED,DELHI vs. DCIT CENTRAL CIRCLE 03, DELHI

ITA 271/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-03, NEW DELHI, DELHI vs. LUV RANJAN, GHAZIABAD

ITA 1845/DEL/2024[2019-20]Status: DisposedITAT Delhi25 Sept 2025AY 2019-20

…efore, expenses entries are only accommodation\nentries.\n\n8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16\nwere deleted by the CIT(A) by relying on the ratio of judgement of Hon'ble\nDelhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421\nwhich was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar\nBuildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that\nassessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much\nbefore the date of search i.e. 28.11.2018 and therefore, the said assessment is\ncompleted assessment. Since no incr…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 2951/DEL/2023[2016-17]Status: DisposedITAT Delhi25 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, NEW DELHI, DELHI vs. BHUSHAN DUA, DELHI

ITA 2950/DEL/2023[2015-16]Status: DisposedITAT Delhi25 Sept 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2018-19 A.Y. 2019-20

…erefore, expenses entries are only accommodation entries. 8.7 The additions so made in AY 2013-14, AY 2014-15 and AY 2015-16 were deleted by the CIT(A) by relying on the ratio of judgement of Hon’ble Delhi High Court in the case of Pr. CIT vs Kabul Chawla 61 Taxmann.com 421 which was upheld by the Supreme Court in the case of Pr CIT Vs Abhishar Buildwell Pvt Ltd vide order dated 24.04.2022. The Ld. CIT(A) highlighted that assessment U/s 143(3) for AY 2013-14 to AY 2015-16 was completed much before the date of search i.e. 28.11.2018 and therefore, the said assessment is completed assessment. Since no incrim…

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