AO cannot assume Section 153C jurisdiction in absence of incriminating documents

Neesa Technologies Pvt. Ltd. Vs DCIT (ITAT Ahmedabad)

Since the proceedings u/s. 153C of the Act were initiated in the present case on the basis of documents which we have held above neither belonged to the assessee nor were incriminating in nature, they were not sufficient for assuming jurisdiction u/s. 153C of the Act. The jurisdiction so assumed in the present case is clearly invalid and the assessment framed accordingly is liable to be quashed.

FULL TEXT OF THE ORDER OF ITAT AHMEDABAD

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