In Brief
The Supreme Court dismissed appeals by the Income Tax Commissioner challenging a Tribunal's decision to quash assessments under Section 153C of the Income Tax Act for Assessment Years 2000-01 to 2003-04. The Court held that a necessary prerequisite for initiating proceedings under Section 153C is that seized material must pertain to the assessment years in question and belong to a third party. Since seized documents had no nexus with the disputed assessment years, the notice was invalid. The Court upheld the Tribunal's right to raise this jurisdictional defect as an additional ground. However, the Court clarified that findings regarding the trust's genuineness and denial of charitable exemption remain valid for other assessment years and ongoing proceedings.
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