Public information & unrelated third-party data not justifies Section 153C SCN

Sandhya Maulik Patel Vs ACIT (Gujarat High Court) The present writ petitions arise from notices issued under Section 153C of the Income-tax Act, 1961 (“the Act”) dated 13 October 2021 by the Assessing Officer (AO) for Assessment Years (AY) 2014-15 to 2020-21. The petitions were filed in response to the issuance of these show-cause notices following a search conducted under Section 132 of the Act at the premises of a land broker and financer, Shri Dhaval Teli, Ahmedabad, on 15 October 2019. During the search, digital data and images from Shri Dhaval Teli’s mobile phone were acquired. Base...