U/s 153C Assessments Quashed – Mere Seized Material Not Enough Unless AO Shows Its Bearing on Total Income

DCIT Vs JFC Finance (India) Limited (ITAT Delhi) The Delhi ITAT quashed the assessments framed under Section 153C in the cases of JFC Finance (India) Ltd. and Alok Dhir arising from the Alankit Group search, holding that the satisfaction note failed to establish how the seized material had any “bearing on the determination of total income” of the assessees. The Tribunal noted that the satisfaction note merely referred to documents and ledger entries allegedly found during search, but did not demonstrate year-wise nexus or incriminating relevance to the assessees’ income. Relying heavily ...