The High Court dismissed the Department’s appeal, holding that  no incriminating material had been brought on record by the Assessing Officer to sustain the additions on the merits, that the genuineness of the share capital  and there was no live link between the seized material and the additions made, and that therefore, the assumption of jurisdiction was erroneous. SLP of Revenue dismissed. Followed   CIT v. Sinhgad Technical Education Society Ltd  (2017)  397 ITR 344 (SC)  wherein the  Court held that  seized material can be considered to be incriminating  in terms section 153C  of the Act, only if the material pertains to the assessment  years in question.   (AY.2010-11 to 2012-13)