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Seized Document's Ownership Dispute: Assessing Officer's Lack of Evidence u/ss 153A, 132(4A)(i), and 292C(1)(i) Raises Questions.
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....Validity of assessment u/s 153A - ‘Document’ was seized during the course of the search proceedings from the premises of Cosmos group, therefore, as per Sec. 132(4A)(i) and Sec. 292C(1)(i) of the Act, the normal presumption would be that the said ‘document’ belonged to the said searched person i.e Cosmos group. Nothing is discernible from the “satisfaction note” as to how the aforesaid presumption was rebutted by the A.O, and on what basis the seized document which was generated, created, maintained and retrieved from the e-mail account of the assessee, from its office premises, was held by the A.O as belonging to the assessee and not the searched person i.e Cosmos group.....