Third-party search material must directly connect the assessed person; unrelated MoU and post-search data cannot support Section 153C notices.

Section 153C assessment notices require incriminating material found during a third-party search to relate to or pertain to the person against whom proceedings are initiated. The notes state that mobile images of an MoU involved other persons and did not connect the petitioners to the transaction; the broker disclaimed involvement, while land records and sale-deed details came from post-search or public-domain sources. A presumed difference between consideration in the unrelated MoU and the registered sale deed could not establish undisclosed investment or the required live nexus. The Gujarat HC therefore quashed the notices as without jurisdiction.

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Issues: Whether notices initiating assessment proceedings against the petitioners under Section 153C could be sustained where material found in the search of a third person had no nexus with them.

Analysis: The seized mobile images comprised an MoU between persons other than the petitioners and did not mention or connect them with the transaction. The broker stated that he had not brokered the transaction, while land-record forms were supplied after the search and the sale-deed details were independently obtained from the public domain. The inference of undisclosed investment was founded only on a presumed difference between the consideration in the unrelated MoU and the consideration in the petitioners' registered sale deed. No incriminating material found during the search related to or pertained to the petitioners, and the post-search information did not establish the requisite live nexus for jurisdictional satisfaction.

Conclusion: The notices under Section 153C were without jurisdiction and were quashed.

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