Section 153C: ITAT Delhi dismisses Revenue’s Appeal due to Lack of Jurisdiction

ACIT Vs Cogent Realtors Pvt. Ltd. (ITAT Delhi) The appeal centered around the jurisdiction under Section 153C of the Income Tax Act and the presence of incriminating material. The ITAT found that there was a lack of jurisdiction due to the absence of incriminating material and deemed the disallowance made by the Assessing Officer as unsustainable. Analysis: During a search and seizure operation, certain documents were seized that were deemed to have a bearing on the determination of the assessee’s total income. However, the ITAT determined that the seized documents did not relate to the ...