https://www.taxtmi.com/caselaws?id=766322 The Delhi HC upheld the Tribunal's decision annulling assessments under Section 153C. The Court held that proceedings under Section 153C cannot be initiated mechanically without the AO forming an opinion that seized material impacts assessment. No incriminating material was found during search pertaining to the relevant assessment years. The provisional balance sheet could not reflect affairs of AYs 2004-05 and 2005-06 as it did not display carried forward or past income/expenditure entries. The primordial requirement of material relating to undisclosed income existed even before 2015 amendments. Decision favored assessee against revenue. en-us Thu, 13 Feb 2025 00:00:00 +0530 Sat, 22 Feb 2025 08:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766322 The Delhi HC upheld the Tribunal's decision annulling assessments under Section 153C. The Court held that proceedings under Section 153C cannot be initiated mechanically without the AO forming an opinion that seized material impacts assessment. No incriminating material was found during search pertaining to the relevant assessment years. The provisional balance sheet could not reflect affairs of AYs 2004-05 and 2005-06 as it did not display carried forward or past income/expenditure entries. The primordial requirement of material relating to undisclosed income existed even before 2015 amendments. Decision favored assessee against revenue. Case-Laws Income Tax Thu, 13 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766322