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HC ruled on validity of assessment under Section 153C, clarifying that discovery of documents pertaining to third parties during search operations triggers jurisdiction, regardless of relationship between searched and non-searched entities. The provision's applicability depends solely on finding incriminating material likely to impact non-searched entity's income assessment. Court rejected argument requiring connection between searched and non-searched parties, emphasizing that Section 153C specifically addresses materials belonging to unrelated third parties. Assessing Officer's obligation extends only to evaluating if discovered materials affect total income determination of non-searched entity. Reading requirement of relationship between parties would contradict statutory purpose. Writ petition dismissed, upholding validity of Section 153C proceedings.
HC ruled on validity of assessment under Section 153C, clarifying that discovery of documents pertaining to third parties during search operations triggers jurisdiction, regardless of relationship between searched and non-searched entities. The provision's applicability depends solely on finding incriminating material likely to impact non-searched entity's income assessment. Court rejected argument requiring connection between searched and non-searched parties, emphasizing that Section 153C specifically addresses materials belonging to unrelated third parties. Assessing Officer's obligation extends only to evaluating if discovered materials affect total income determination of non-searched entity. Reading requirement of relationship between parties would contradict statutory purpose. Writ petition dismissed, upholding validity of Section 153C proceedings.
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