https://www.taxtmi.com/highlights?id=94164 HC held that invocation of section 153C requires concurrent satisfaction by the AOs of the searched person and the non-searched person that seized property or documents relate to a person other than the searched person; no such satisfaction was recorded. The impugned assessment did not rest on incriminating material found against the petitioner during search/seizure, but on information from the investigation unit and evidence collected during and after search proceedings. Consequently, the assessment under section 147 was proper and invocation of sections 153A/153C was unwarranted. The petitioner's challenge to framing proceedings under section 153C was rejected and the assessment under section 147 upheld. en-us Fri, 14 Nov 2025 09:42:55 +0530 Fri, 14 Nov 2025 09:42:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94164 HC held that invocation of section 153C requires concurrent satisfaction by the AOs of the searched person and the non-searched person that seized property or documents relate to a person other than the searched person; no such satisfaction was recorded. The impugned assessment did not rest on incriminating material found against the petitioner during search/seizure, but on information from the investigation unit and evidence collected during and after search proceedings. Consequently, the assessment under section 147 was proper and invocation of sections 153A/153C was unwarranted. The petitioner's challenge to framing proceedings under section 153C was rejected and the assessment under section 147 upheld. Highlights Income Tax Fri, 14 Nov 2025 09:42:55 +0530 https://www.taxtmi.com/highlights?id=94164