Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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For invoking jurisdiction under section 153C, satisfaction must be specific, based on cogent material, and must show that the seized material pertains to the assessee and affects total income for the relevant year. A common, mechanical satisfaction note covering multiple years, without year-specific incriminating documents or prima facie analysis of undisclosed income, was found insufficient. A third-party ledger, unsupported by independent corroboration or meaningful enquiry, was not treated as incriminating. Because the assessment year was unabated and year-specific satisfaction was absent, the notice and assessment were quashed, while the merits of the additions were left open.
For invoking jurisdiction under section 153C, satisfaction must be specific, based on cogent material, and must show that the seized material pertains to the assessee and affects total income for the relevant year. A common, mechanical satisfaction note covering multiple years, without year-specific incriminating documents or prima facie analysis of undisclosed income, was found insufficient. A third-party ledger, unsupported by independent corroboration or meaningful enquiry, was not treated as incriminating. Because the assessment year was unabated and year-specific satisfaction was absent, the notice and assessment were quashed, while the merits of the additions were left open.
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