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HC held proceedings under Section 153C invalid as no incriminating material pertaining to assessed years was discovered during search. The provisional balance sheet found did not reflect affairs of AYs 2004-05 and 2005-06 or display carried forward entries. The requirement that seized material must relate to undisclosed income predated the 2015 amendments adding "have a bearing on" language. The AO of non-searched person must form opinion that material impacts assessment before initiating proceedings. Mere mechanical transmission of documents without substantive connection to undisclosed income insufficient. ITAT correctly annulled assessment. Appeal dismissed in favor of assessee.
HC held proceedings under Section 153C invalid as no incriminating material pertaining to assessed years was discovered during search. The provisional balance sheet found did not reflect affairs of AYs 2004-05 and 2005-06 or display carried forward entries. The requirement that seized material must relate to undisclosed income predated the 2015 amendments adding "have a bearing on" language. The AO of non-searched person must form opinion that material impacts assessment before initiating proceedings. Mere mechanical transmission of documents without substantive connection to undisclosed income insufficient. ITAT correctly annulled assessment. Appeal dismissed in favor of assessee.
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