Dismissing the appeal of the revenue the Court held that ,as no satisfaction was recorded sating that how seized material belonged to the assssee . Accordingly in the absence of any incriminating material , notice was held to ne in valid .( AY.2009-10)
CIT v. N. S. Software (FIRM) (2018) 403 ITR 259 / 165 DTR 201 / 302 CTR 136 / 255 Taxman 230(Delhi) (HC)
S. 153C : Assessment – Income of any other person – Search – No satisfaction was recorded sating that how seized material belonged to the assssee. In the absence of any incriminating material , notice was held to ne in valid [ S. 132 ]