Addition can’t be made based on search & seizure action taken against a third party without categorical finding that the search material pertains to the assessee

 RELEVANT PARAGRAPH 9. I have gone through the records carefully and I am unable to find any reason for making addition in the hands of the assessee. The addition is based upon the search proceedings and seizure that took place in the case of Narendra Kumar Paraswani not in the hands of the firm. Even the statement that were recorded have not implicated the assessee in any manner. The assessee is a firm. If at all, there are any family partition, I do not consider why the firm is required to explain that. In other words, the addition made u/s 158BC in respect of this document cannot be suppor...