Ronak Processors (P) Ltd v. ITO (2021) 209 TTJ 641 / 197 DTR 377 (Jodhpur)(Trib.)

S. 153C : Assessment-Income of any other person-Search-Documents found in the premises of third party-Addition on the basis of such documents are held to be not valid [S. 132(4A), 292C]

On the basis of documents found in the premises of S.P. Bajaj addition cannot be made on the presumption that the documents belongs to the appellant. The provision of section 132(4A) and section 292C the presumption is that seized documents belong to the person in whose possession they are found cannot be made applicable to the appellant. Addition made on the said documents are deleted. (AY. 2009-10)