https://www.taxtmi.com/caselaws?id=788351 For invoking section 153C, the seized material must be incriminating and have a direct nexus with the non-searched person's income; a mechanical satisfaction note is insufficient, and assessments beyond the applicable ten-year block period are invalid. On the facts, the excel sheet did not name the assessee, was not shown to be a contemporaneous business record, and did not establish that the material belonged to, pertained to, or related to the assessee. The jurisdictional assumption failed and the assessments were quashed. The additions also failed on merits because the document and accompanying statements lacked reliable corroboration and could not sustain alleged commission income or unexplained credits. en-us Fri, 06 Feb 2026 00:00:00 +0530 Wed, 18 Mar 2026 16:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788351 For invoking section 153C, the seized material must be incriminating and have a direct nexus with the non-searched person's income; a mechanical satisfaction note is insufficient, and assessments beyond the applicable ten-year block period are invalid. On the facts, the excel sheet did not name the assessee, was not shown to be a contemporaneous business record, and did not establish that the material belonged to, pertained to, or related to the assessee. The jurisdictional assumption failed and the assessments were quashed. The additions also failed on merits because the document and accompanying statements lacked reliable corroboration and could not sustain alleged commission income or unexplained credits. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788351