https://www.taxtmi.com/caselaws?id=785870 Assessment under the tax code cannot be grounded on documents seized from third-party premises unless those materials, on their face or by reliable corroboration, indicate they belong to or pertain to the taxpayer. The statutory presumptions favour the searched person for documents found in their possession; it was for that person or the revenue to rebut the presumption with tangible evidence showing the material related to the taxpayer. Private notings or diaries without independent linkage are "dumb documents" and lack evidentiary value. Because the seized electronic and account-book entries contained no clear identifier or corroboration tying them to the taxpayer, invoking jurisdiction to assess the taxpayer was void and the assessment was quashed. en-us Thu, 22 Jan 2026 00:00:00 +0530 Sun, 01 Feb 2026 18:01:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785870 Assessment under the tax code cannot be grounded on documents seized from third-party premises unless those materials, on their face or by reliable corroboration, indicate they belong to or pertain to the taxpayer. The statutory presumptions favour the searched person for documents found in their possession; it was for that person or the revenue to rebut the presumption with tangible evidence showing the material related to the taxpayer. Private notings or diaries without independent linkage are "dumb documents" and lack evidentiary value. Because the seized electronic and account-book entries contained no clear identifier or corroboration tying them to the taxpayer, invoking jurisdiction to assess the taxpayer was void and the assessment was quashed. Case-Laws Income Tax Thu, 22 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785870