To acquire section 153C Jurisdiction, Documents Seized must be Incriminating

ACIT Vs Realtech Construction Pvt. Ltd. (ITAT Delhi) The issue under consideration is whether to acquire jurisdiction under section 153C is it require that the seized documents must be incriminating and must relate to the assessment year whose assessment were sought to be reopened? ITAT states that from a bare perusal of the satisfaction note, it could be seen that the seized documents were mainly MOU’s between promoters of Realtech group, namely, Y, P and R along with the some working of the Realtech Group. There was no reference in the assessment order or in the seized documents that t...