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Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
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