Invocation of section 153C requires concurrent AO satisfaction; failure led to upholding assessment under section 147

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....HC held that invocation of section 153C requires concurrent satisfaction by the AOs of the searched person and the non-searched person that seized property or documents relate to a person other than the searched person; no such satisfaction was recorded. The impugned assessment did not rest on incriminating material found against the petitioner during search/seizure, but on information from the investigation unit and evidence collected during and after search proceedings. Consequently, the assessment under section 147 was proper and invocation of sections 153A/153C was unwarranted. The petitioner's challenge to framing proceedings under section 153C was rejected and the assessment under section 147 upheld.....