Assessment u/s 153C based on incriminating documents not related to assessment years under appeals was invalid

M/s. Wisdom Realtors Pvt. Vs ACIT (ITAT Delhi) Conclusion: Since assessment under section 153C was made only on the basis of incriminating documents such as balance sheet and profit and loss account which were not related to assessment years under appeals, therefore, assessment was invalid as no incriminating material was found during the course of search to proceed against the assessee. Held: AO initiated search proceedings under section 153C  against the assessee by recording satisfaction that  the incriminating documents belonged to assessee-company. It was held only incriminating docum...