HC held that no incriminating material "relating to" or "pertaining to" the assessees was found during search on the third party, as the relevant land records were supplied post-search and sale deed details were sourced from the public domain. Such material did not establish a live link or nexus with any undisclosed income of the assessees, rendering the presumption of escaped assessment based on the alleged undervaluation unsustainable. Consequently, the satisfaction recorded u/s 153C was held to be de hors the statute and without jurisdiction. The impugned notices issued u/s 153C were quashed and set aside.
HC held that no incriminating material "relating to" or "pertaining to" the assessees was found during search on the third party, as the relevant land records were supplied post-search and sale deed details were sourced from the public domain. Such material did not establish a live link or nexus with any undisclosed income of the assessees, rendering the presumption of escaped assessment based on the alleged undervaluation unsustainable. Consequently, the satisfaction recorded u/s 153C was held to be de hors the statute and without jurisdiction. The impugned notices issued u/s 153C were quashed and set aside.
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