The HC held that for an AO to assume jurisdiction under Section...

The HC held that for an AO to assume jurisdiction under Section 153C, the incriminating material seized during a search must have a direct bearing on the total income of the non-searched person. The court emphasized that the AO must be satisfied that the seized books, documents, or assets relate to the income determination of the other person before issuing a notice under Section 153C. Mere presence of information concerning the non-searched person in the seized material is insufficient without this satisfaction. The contention that the AO need not be satisfied about the bearing of the information on the non-searched person's income was rejected as contrary to the statutory language. Consequently, the impugned notice(s) issued under Section 153C were quashed.

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