https://www.taxtmi.com/caselaws?id=782300 ITAT Delhi quashed the assessment u/s 153C against the assessee company, holding that the jurisdictional requirement of seized material "belonging to" the assessee was not satisfied. The seized ledger only recorded a payment received from a third party and did not name or identify the assessee. The satisfaction note was based on a letter dated 16.06.2014 allegedly filed by the assessee, but evidence showed it was filed by another group of companies, which had already owned up the transactions. As the satisfaction note was factually incorrect and the seized documents had been considered in assessments of that group, additions in the assessee's hands were held unsustainable. en-us Wed, 19 Nov 2025 00:00:00 +0530 Thu, 27 Nov 2025 08:36:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782300 ITAT Delhi quashed the assessment u/s 153C against the assessee company, holding that the jurisdictional requirement of seized material "belonging to" the assessee was not satisfied. The seized ledger only recorded a payment received from a third party and did not name or identify the assessee. The satisfaction note was based on a letter dated 16.06.2014 allegedly filed by the assessee, but evidence showed it was filed by another group of companies, which had already owned up the transactions. As the satisfaction note was factually incorrect and the seized documents had been considered in assessments of that group, additions in the assessee's hands were held unsustainable. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782300