https://www.taxtmi.com/caselaws?id=780753 ITAT (Del AT) set aside the AO's action under ss.153A r.w.s.153C, holding the satisfaction note vague and insufficient to assume jurisdiction. While acknowledging the SC view that material at third-party premises is "found in the course of search," the Tribunal held the AO must verify whether documents relate to the searched person and follow the due process before treating them as incriminating or initiating proceedings. Material seized from a searched person but relating to others must be forwarded to the respective AO, who must independently record satisfaction. Additional grounds of the assessee were allowed. en-us Wed, 15 Oct 2025 00:00:00 +0530 Tue, 04 Nov 2025 15:46:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780753 ITAT (Del AT) set aside the AO's action under ss.153A r.w.s.153C, holding the satisfaction note vague and insufficient to assume jurisdiction. While acknowledging the SC view that material at third-party premises is "found in the course of search," the Tribunal held the AO must verify whether documents relate to the searched person and follow the due process before treating them as incriminating or initiating proceedings. Material seized from a searched person but relating to others must be forwarded to the respective AO, who must independently record satisfaction. Additional grounds of the assessee were allowed. Case-Laws Income Tax Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780753