https://www.taxtmi.com/caselaws?id=470668 Assessment based on material seized from a person other than the assessee falls within the framework of Section 153C, not Section 153A, where no incriminating material is found from the assessee. An alleged partnership does not change the assessee's status for this purpose. Seized documents that are not regular books or transaction records cannot support additions without independent evidence linking them to undisclosed income or expenditure. The rebuttable presumption under Section 132(4A) applies against the person from whose possession the material was found and cannot, without corroboration, justify additions against another person. Selective reliance on uncorroborated material is impermissible. en-us Fri, 30 Jun 2023 00:00:00 +0530 Tue, 04 Aug 2026 11:35:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470668 Assessment based on material seized from a person other than the assessee falls within the framework of Section 153C, not Section 153A, where no incriminating material is found from the assessee. An alleged partnership does not change the assessee's status for this purpose. Seized documents that are not regular books or transaction records cannot support additions without independent evidence linking them to undisclosed income or expenditure. The rebuttable presumption under Section 132(4A) applies against the person from whose possession the material was found and cannot, without corroboration, justify additions against another person. Selective reliance on uncorroborated material is impermissible. Case-Laws Income Tax Fri, 30 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470668