PCIT v. S.R. Trust (2021) 438 ITR 506/ 277 Taxman 133/ 208 DTR 325 / 323 CTR 1047 (Mad.)(HC)

S. 153C : Assessment-Income of any other person-Search and Seizure-In absence of any incriminating documents or evidence discovered against assesse the assessment is bad in law. [S. 12AA, 132]

Dismissing the appeal of the revenue the Court held that in absence of any incriminating documents or evidence discovered against assessee, during search upon TJR, jurisdiction under provisions of section 153C could not be assumed against assessee.