No assessment u/s 153C if Revenue failed to discharge onus to show incriminating material belonged to assessee

Karina Airlines Intenational Vs ACIT (ITAT Delhi) Conclusion: Onus was on Revenue to show that the incriminating material/documents recovered at the time of search ‘belongs’ to the Assessee, in other words, it was not enough for the Revenue to show that the documents either ‘pertain’ to the Assessee or contains information that ‘relates to the Assessee. Also, the date of satisfaction recorded by AO of assessee on 15/5/2019 fell in the assessment year 2020-21 in which case the immediately preceding 6 assessment years would be the assessment years from 2014- 15 to 2019-20. It was, ther...