https://www.taxtmi.com/caselaws?id=353509 No addition can be sustained where impugned documents were recovered from a third-party premises but no substituted assessment was completed in the taxpayers case and no recorded satisfaction linking the documents to the taxpayer was produced. The legal basis requires that when documents seized from a third party are relied upon, the revenue must complete assessment under the substituted assessment procedure and establish ownership nexus of the documents; absent completion of that procedure and recorded satisfaction, the addition is unsupportable and the taxpayer succeeds. en-us Thu, 04 Jan 2018 00:00:00 +0530 Tue, 27 Jan 2026 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353509 No addition can be sustained where impugned documents were recovered from a third-party premises but no substituted assessment was completed in the taxpayers case and no recorded satisfaction linking the documents to the taxpayer was produced. The legal basis requires that when documents seized from a third party are relied upon, the revenue must complete assessment under the substituted assessment procedure and establish ownership nexus of the documents; absent completion of that procedure and recorded satisfaction, the addition is unsupportable and the taxpayer succeeds. Case-Laws Income Tax Thu, 04 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353509