Court Rules AO Failed to Prove Seized Material Belonged to Assessee, Section 153C Proceedings Invalidated.

Court Rules AO Failed to Prove Seized Material Belonged to Assessee, Section 153C Proceedings Invalidated. https://www.taxtmi.com/highlights?id=67122 Assumption of jurisdiction under 153C - assessment in search cases - Even as per the pre-amended provisions of Section 153C, AO has to record satisfaction to the effect that seized material "belongs" or "belongs to" other person. In this case, the A.O. has not put on record that any material seized during the course of search does belong to the assessee. However seized materials related to other third party. Therefore in our considered view, the invocation of proceedings u/s. 153C is against the provisions of law. - AT en-us Thu, 15 Dec 2022 13:17:38 +0530 Thu, 15 Dec 2022 13:17:38 +0530 TaxTMI RSS Generator Court Rules AO Failed to Prove Seized Material Belonged to Assessee, Section 153C Proceedings Invalidated. https://www.taxtmi.com/highlights?id=67122 Assumption of jurisdiction under 153C - assessment in search cases - Even as per the pre-amended provisions of Section 153C, AO has to record satisfaction to the effect that seized material "belongs" or "belongs to" other person. In this case, the A.O. has not put on record that any material seized during the course of search does belong to the assessee. However seized materials related to other third party. Therefore in our considered view, the invocation of proceedings u/s. 153C is against the provisions of law. - AT Highlights Income Tax Thu, 15 Dec 2022 13:17:38 +0530 https://www.taxtmi.com/highlights?id=67122