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Section 153C distinguishes a searched person from an other...
Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported profit additions.
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Section 153C distinguishes a searched person from an other person by the name in the search warrant and the statutory satisfaction recorded; ownership or occupation of searched premises alone does not confer searched-person status. For completed or unabated assessment years, additions must rest on incriminating material found during search that pertains to each relevant year. Material relating to a later year and uncorroborated general admissions cannot support additions for earlier years. In liquor-business profit estimation, commercially plausible indirect expenses cannot be rejected outright solely because complete vouchers are unavailable, and separate addition of expenses already excluded in computing net profit results in impermissible double addition.
Section 153C distinguishes a searched person from an other person by the name in the search warrant and the statutory satisfaction recorded; ownership or occupation of searched premises alone does not confer searched-person status. For completed or unabated assessment years, additions must rest on incriminating material found during search that pertains to each relevant year. Material relating to a later year and uncorroborated general admissions cannot support additions for earlier years. In liquor-business profit estimation, commercially plausible indirect expenses cannot be rejected outright solely because complete vouchers are unavailable, and separate addition of expenses already excluded in computing net profit results in impermissible double addition.
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