Assessments u/s 153C: AO Must Present Strong Evidence to Prove Document Belongs to Another Party.

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....Assessment u/s 153C - the normal presumption is that document belongs to searched person. It is for the AO to rebut that presumption and come to a conclusion or "satisfaction" that the document in fact belongs to somebody else based on some cogent material - no error much less an error of law could be said to have been committed in taking the view that there is no cogent material for arriving at the substantive satisfaction....