ITAT says Unabated Assessments Cannot Be Reopened Without Incriminating Material

Tater Realty's AYs 2013-14 and 2014-15 assessments had become unabated when search proceedings were conducted. The Tribunal held that the unsecured loans were already reflected in the books and that statements, post-search enquiries, third-party material and assessment-stage investigations did not constitute incriminating material found during the assessee's search. The Section 68 additions and consequential Section 69C interest disallowances were therefore deleted.