Material gathered in search with no correlation to assessee cannot be said to pertain to assessee

PCIT Vs Divine Developwell Pvt Ltd (Delhi High Court)

In the case of PCIT vs. Divine Developwell Pvt. Ltd. Hon’ble Delhi High Court held that the documents which were seized during the course of search does was unsigned Agreement to sell (ATS) which does not contain name of assessee, the said material cannot be said to pertain/pertains to assessee.

The ITAT’s examination focused on the satisfaction note, which formed the basis for initiating proceedings under Section 153C of the Act. This note highlighted an unsigned Agreement to Sell (ATS) dated

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