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The SC dismissed the Special Leave Petitions and declined to interfere with the High Court's order, upholding that assessment proceedings under section 153C can only be initiated where seized or received material is identified as incriminating with respect to specific assessment year(s) or is likely to affect the computation of total income for those year(s). The Assessing Officer must be satisfied that the material bears on particular year(s) within the relevant block before issuing a notice under section 153C; the AO's jurisdiction is confined to those year(s). In the absence of material likely to cast doubt on the estimation of income for particular year(s), invocation of section 153C is not justified. Pending applications disposed of.
The SC dismissed the Special Leave Petitions and declined to interfere with the High Court's order, upholding that assessment proceedings under section 153C can only be initiated where seized or received material is identified as incriminating with respect to specific assessment year(s) or is likely to affect the computation of total income for those year(s). The Assessing Officer must be satisfied that the material bears on particular year(s) within the relevant block before issuing a notice under section 153C; the AO's jurisdiction is confined to those year(s). In the absence of material likely to cast doubt on the estimation of income for particular year(s), invocation of section 153C is not justified. Pending applications disposed of.
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