The Assessing Officer in the assessment order has not referred to any seized material found during the course of second search pertaining to assessee company which gave any clue even in a remotest manner with respect to payment of interest on PDCs out of books beyond six months from the sale deed, no addition could have been sustained. The decisions relied on by the Id. counsel for the assessee also support its case that addition cannot be made for a particular year without there being any incriminating material qua that assessment year which would justify such addition. Accordingly, the ground raised by the assessee is allowed.