In Brief
Sri Sai Cashews, a cashew processing firm, challenged an income tax assessment order initiated under Section 153C following searches of two unrelated persons. The Court held that Section 153C permits initiating assessment against a third party only when incriminating materials concerning that person are found during the search of another and recorded in a satisfaction note. The presumption that seized documents belong to the searched person can be rebutted only with cogent material, not surmise. Since no incriminating materials concerning the petitioner were found from the searched persons, the assessment order lacked legal foundation and was set aside.
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