https://www.taxtmi.com/caselaws?id=457869 The ITAT Delhi quashed assessment proceedings initiated under section 153C, ruling that the AO's assumption of jurisdiction was invalid. The tribunal found that an unsigned MOU dated 30.11.2012, seized from a third party's premises, could not serve as basis for proceedings. The document lacked essential details including dates and proper signatures, with the person from whose premises it was seized not having signed it. The AO failed to record statements from relevant parties and acted hastily without proper application of mind. The tribunal held that mere seizure of an incomplete, legally unenforceable document mentioning cash amounts without supporting details was insufficient to justify section 153C proceedings. The entire assessment was vitiated due to wrong jurisdictional assumption. Appeal allowed. en-us Fri, 05 Apr 2024 00:00:00 +0530 Sun, 29 Sep 2024 16:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457869 The ITAT Delhi quashed assessment proceedings initiated under section 153C, ruling that the AO's assumption of jurisdiction was invalid. The tribunal found that an unsigned MOU dated 30.11.2012, seized from a third party's premises, could not serve as basis for proceedings. The document lacked essential details including dates and proper signatures, with the person from whose premises it was seized not having signed it. The AO failed to record statements from relevant parties and acted hastily without proper application of mind. The tribunal held that mere seizure of an incomplete, legally unenforceable document mentioning cash amounts without supporting details was insufficient to justify section 153C proceedings. The entire assessment was vitiated due to wrong jurisdictional assumption. Appeal allowed. Case-Laws Income Tax Fri, 05 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457869