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ITAT ruled that seized documents from Micromax premises cannot be used against the assessee under Section 153A. The panchanama did not include the assessee's name, and the documents were found during an independent search of a third-party company. The Tribunal held that such documents can only be utilized under Section 153C after the AO records satisfaction that the documents relate to another person. The procedural requirement mandates a separate proceeding and independent satisfaction by the AO before initiating assessment. Consequently, the AO's assessment order was deemed improper, and the assessee's appeal was allowed.
ITAT ruled that seized documents from Micromax premises cannot be used against the assessee under Section 153A. The panchanama did not include the assessee's name, and the documents were found during an independent search of a third-party company. The Tribunal held that such documents can only be utilized under Section 153C after the AO records satisfaction that the documents relate to another person. The procedural requirement mandates a separate proceeding and independent satisfaction by the AO before initiating assessment. Consequently, the AO's assessment order was deemed improper, and the assessee's appeal was allowed.
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