Income Tax Assessment Valid When Search Reveals Third-Party Documents Under Section 153C Without Requiring Entity Relationship
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....HC ruled on validity of assessment under Section 153C, clarifying that discovery of documents pertaining to third parties during search operations triggers jurisdiction, regardless of relationship between searched and non-searched entities. The provision's applicability depends solely on finding incriminating material likely to impact non-searched entity's income assessment. Court rejected argument requiring connection between searched and non-searched parties, emphasizing that Section 153C specifically addresses materials belonging to unrelated third parties. Assessing Officer's obligation extends only to evaluating if discovered materials affect total income determination of non-searched entity. Reading requirement of relationship between parties would contradict statutory purpose. Writ petition dismissed, upholding validity of Section 153C proceedings.....