https://www.taxtmi.com/caselaws?id=782757 Section 153C assessment notices require incriminating material found during a third-party search to relate to or pertain to the person against whom proceedings are initiated. The notes state that mobile images of an MoU involved other persons and did not connect the petitioners to the transaction; the broker disclaimed involvement, while land records and sale-deed details came from post-search or public-domain sources. A presumed difference between consideration in the unrelated MoU and the registered sale deed could not establish undisclosed investment or the required live nexus. The Gujarat HC therefore quashed the notices as without jurisdiction. en-us Mon, 24 Nov 2025 00:00:00 +0530 Wed, 15 Jul 2026 10:22:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782757 Section 153C assessment notices require incriminating material found during a third-party search to relate to or pertain to the person against whom proceedings are initiated. The notes state that mobile images of an MoU involved other persons and did not connect the petitioners to the transaction; the broker disclaimed involvement, while land records and sale-deed details came from post-search or public-domain sources. A presumed difference between consideration in the unrelated MoU and the registered sale deed could not establish undisclosed investment or the required live nexus. The Gujarat HC therefore quashed the notices as without jurisdiction. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782757