Proceedings u/s. 153C cannot be triggered without formation of opinion by AO of non-searched person

PCIT Vs Ridgeview Construction Pvt. Ltd (Delhi High Court) Facts- The Principal Commissioner of Income Tax seeks to impugn the order of the Income Tax Appellate Tribunal dated 31 October 2018 and which has upheld the stand as taken by the respondent-assessee of the material seized in the course of a search not being incriminating and thus not justifying the initiation of assessment proceedings referable to Section 153C of the Income Tax Act, 1961, as it stood at the relevant time. Conclusion- Delhi High Court held that Section 153C as application at relevant time didn’t contemplate two tier ...