Diary Entries Alone Insufficient to Trigger Section 153C Proceedings

Shabnam Bharatinder Singh Vs DCIT (ITAT Delhi) Invalid 153C Satisfaction Sinks Entire Assessment: Diary Must Have “Bearing on Total Income” Search was conducted on Kuldeep Bishnoi Group, during which a diary belonging to Late Shri Sukumar Poria was seized. On the basis of certain notings in the diary, AO initiated proceedings u/s 153C against Assessee, alleging unaccounted cash receipts & made additions treating entries as undisclosed income. CIT(A) upheld the action. ITAT quashed the entire proceedings. Tribunal held that mere recording that seized material “pertains to” the Asses...