The Assessee was a medical charitable trust registered under section 12AA, running a multi-specialty hospital. A search action was conducted in case of third party who was a supplier of medical, surgical equipment and other accessories to hospital .On the basis of certain documents seized during search, AO concluded that assessee had siphoned off funds through said third party, allegedly resorting to huge inflation of expenses .Accordingly, a notice under section 153C was issued against assessee. Being aggrieved by the additions made by the AO, the Assessee made an appeal before the CIT(A), who allowed the appeals filed by the Assessee. The Tribunal found that materials seized did not establish any co-relation, document wise, with the four Assessment Years under consideration and therefore did not indicate any inflation of purchase expenses by assessee trust. The Tribunal further noted that the third had approached the Settlement Commission and submitted an application wherein Commissioner stated that there was no supporting evidence of returning cash withdrawn by the third party to the hospital. Relying on the decision of Hon’ble Supreme Court in the case of CIT v. Sinhagad Technical Education Society (84 Taxmann.com 240) , the Hon’ble Madras High Court held that ,in absence of any incriminating documents or evidence discovered against assessee, during its search upon the third Party, jurisdiction under provisions of section 153C could not be assumed against assessee. Accordingly, the appeals filed by the Revenue were dismissed. (TCAl No.161 to 167 of 2020, dt.24-11-2020) (AY. 2009-10 to 2015-16)