S. 153C List of shareholders maintained by company cannot be said to be belonging to such shareholders

DCIT Vs Esteem Textiles P. Ltd. (ITAT Delhi)  Evidently, AO on the basis of a letter written by the company, which was returned by the assessee by putting its signature and seal in confirmation of the accounts, had framed the assessment under section 153C. However, the said document could not be said to belong to assessee inasmuch as besides assessee there were so many names and it could not be said that these documents belonged to them. It would lead to some absurd conclusions or consequences to say that when a person maintains a list of their shareholders, such document belongs to or pertai...