SBG Infrastructure LLP V. DCIT (2021) 191 ITD 400 (Ahd.) (Trib.)

S. 153C : Assessment-Income of any other person-Search-Unnamed documents-Statement recorded after conclusion of search cannot be consideration as information for invoking the provision of section. 153C of the Act. [S. 131(IA), 132]

Held that the documents were unnamed, therefore, on basis of these documents Assessing Authority could not have reached any firm conclusion that these documents belonged to assessee. There being no material with Assessing Officer to form a belief that action under section 153C was required to be taken against assessee, it had erred in assuming jurisdiction under section 153C of the Act. Tribunal also held that  statement recorded under section 131(1A) after conclusion of search  could not  be an information for invoking section 153C of the Act. (AY. 2012-13 to 2014-15)