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We find that the additions made by the AO are beyond the scope of section 153C of the Income Tax Act, 1961, because no incriminating material or evidence had been found during the course of search so as to doubt the transactions. In the entire assessment order, the AO has not referred to any seized material or other material  having being found during the course of search . Therefore, the action of the AO is not sustainable in the eyes of law.

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Section 153A of the Income Tax Act, 1961 — Search and Seizure — Additions made by the AO were beyond the scope of section 153C because no incriminating material or evidence had been found during the course of search so as to count the transactions and in the entire assessment order, the AO had not referred to any seized material or other material having been found during the course of search in the case of assessee, therefore, action of the AO was based upon conjectures and surmises and the addition made was not sustainable in the eyes of law — Deputy Commissioner of income tax vs. Madhyam Housing P. Ltd. [2019] 76 ITR (trib) 82 (Delhi).

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