Case LawsIncome Tax
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Digital material recovered in a third party search cannot alone justify invoking Section 153C without a direct nexus to the non searched person.
Section 153C jurisdiction requires seized or requisitioned books of account or documents from a search that relate to or pertain to a non searched person; digital images recovered in a third party search that did not name or connect the petitioners could not sustain Section 153C. The Assessing Officer's reliance on post search forms, voluntary supply of documents, public domain inquiries, and an inferential consideration mismatch rendered the recorded satisfaction de hors the statutory trigger, allowing writ relief for jurisdictional defect.