https://www.taxtmi.com/caselaws?id=759132 The ITAT Nagpur-AT allowed the assessee's appeal against additions made under section 153C proceedings. The tribunal held that the documents seized during search were not incriminating as they did not contain the assessee's name or establish any connection to the assessee. The satisfaction note failed to specify how the documents pertained to the assessee or which assessment years were affected. The AO mechanically applied identical orders across multiple entities using the same generic documents. The tribunal found the estimated profitability statement unrealistic as it remained constant for seven years without considering inflation. The assessment was quashed as the foundational requirement for invoking section 153C jurisdiction was missing, since the seized documents neither pertained to the assessee nor impacted income determination. en-us Mon, 02 Sep 2024 00:00:00 +0530 Wed, 25 Sep 2024 08:01:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759132 The ITAT Nagpur-AT allowed the assessee's appeal against additions made under section 153C proceedings. The tribunal held that the documents seized during search were not incriminating as they did not contain the assessee's name or establish any connection to the assessee. The satisfaction note failed to specify how the documents pertained to the assessee or which assessment years were affected. The AO mechanically applied identical orders across multiple entities using the same generic documents. The tribunal found the estimated profitability statement unrealistic as it remained constant for seven years without considering inflation. The assessment was quashed as the foundational requirement for invoking section 153C jurisdiction was missing, since the seized documents neither pertained to the assessee nor impacted income determination. Case-Laws Income Tax Mon, 02 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759132