https://www.taxtmi.com/caselaws?id=396988 For pre-amendment section 153C proceedings, jurisdiction arises only where seized material from a third-party search is shown to belong to the assessee; mere references, without identifying particulars or control by the assessee, are insufficient because "belongs to" is narrower than "relates to" or "pertains to." In addition, an on-money addition for agricultural land purchase cannot be sustained solely on third-party excel sheets and statements unless there is direct corroborative evidence linking the assessee to the alleged cash payment. The commentary emphasises that absence of such linkage and corroboration defeats both jurisdictional assumption and the quantum addition. en-us Mon, 01 Jun 2020 00:00:00 +0530 Tue, 28 Jul 2020 20:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396988 For pre-amendment section 153C proceedings, jurisdiction arises only where seized material from a third-party search is shown to belong to the assessee; mere references, without identifying particulars or control by the assessee, are insufficient because "belongs to" is narrower than "relates to" or "pertains to." In addition, an on-money addition for agricultural land purchase cannot be sustained solely on third-party excel sheets and statements unless there is direct corroborative evidence linking the assessee to the alleged cash payment. The commentary emphasises that absence of such linkage and corroboration defeats both jurisdictional assumption and the quantum addition. Case-Laws Income Tax Mon, 01 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396988