https://www.taxtmi.com/caselaws?id=421715 For pre-amendment section 153C proceedings, seized material had to strictly belong to a person other than the searched person; hard disks, emails and invoices found in the searched party's premises or email accounts did not satisfy that test, and the later "pertains to or relates to" wording was treated as prospective. The jurisdictional condition for section 153C therefore failed and the assessment was quashed. On merits, a French resident providing independent professional architectural services was entitled to Article 15 treaty protection, so the assessee could not be fastened with tax as representative assessee or agent under section 163 absent the necessary statutory conditions. The related addition was deleted. en-us Wed, 27 Apr 2022 00:00:00 +0530 Sat, 30 Apr 2022 08:10:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421715 For pre-amendment section 153C proceedings, seized material had to strictly belong to a person other than the searched person; hard disks, emails and invoices found in the searched party's premises or email accounts did not satisfy that test, and the later "pertains to or relates to" wording was treated as prospective. The jurisdictional condition for section 153C therefore failed and the assessment was quashed. On merits, a French resident providing independent professional architectural services was entitled to Article 15 treaty protection, so the assessee could not be fastened with tax as representative assessee or agent under section 163 absent the necessary statutory conditions. The related addition was deleted. Case-Laws Income Tax Wed, 27 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421715