Case Law Analysis
|Income Tax Appellate Tribunal
Section 153C Income Tax Act | Assessment Invalid Without Incriminating Material Belonging to Assessee Found During Third-Party Search : ITAT Delhi
The ITAT Delhi has ruled that an assessment under Section 153C cannot stand unless incriminating material directly belonging to the assessee is discovered during a search of a third party. This clarifies a critical jurisdictional limit on the tax department’s power to reassess unrelated taxpayers, reinforcing natural justice and statutory compliance in income tax proceedings.