Annual Report & Share Certificate cannot be treated as Incriminating Documents if no link with addition

PCIT Vs Panchmukhi Management Services Pvt. Ltd. (Delhi High Court) Seized material can be considered to be incriminating only if it pertains to Assessment Years in question Perusal of the satisfaction note reveals that no document pertaining to Assessment Year 2011-12 was seized during search. The Supreme Court in Commissioner of Income Tax-III, Pune Vs. Sinhgad Technical Education Society reported in [2017] 397 ITR 344 has held that seized material can be considered to be incriminating in terms of Section 153C of the Act only if the said material pertains to the Assessment Years in question...