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of The HC affirmed the ITAT's allowance of the assessee's appeal, holding that reassessment framed under s.153A could not be sustained. The tribunal correctly determined that documents retrieved on search-board resolutions, legal notes, valuation reports, deeds of retirement, reconstitution indentures and retirement-cum-release instruments-were business records and not incriminating material. There was no evidence of concealment, nor did the conversion of the partnership to a company constitute a capital asset 'transfer' as contemplated by s.2(47). Consequently, consequential reassessment proceedings lacked jurisdictional and substantive basis and were quashed, with the assessment restored in favour of the assessee.
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