Tribunal held that the Department had failed to bring any material on record to establish that any seized documents found during the course of search belonged to the assessee. There was a clear finding by the Commissioner (Appeals) in his order that none of the seized documents referred to the assessee which the Department was unable to controvert.(AY.2006-07, 2007-08)
Green Valley Tower Pvt. Ltd. v. ACIT (2021) 86 ITR 1 (Delhi)(Trib.)
S. 147 : Reassessment-Search and seizure-Seized ground not related to the assessee-Reassessment is bad in law. [S. 132]