Addition of Rs. 46.87 Lakhs Based on Partner’s Seized Documents: ITAT Quashes Assessment for Bypassing S.153C Procedure

The ITAT (Income Tax Appellate Tribunal) has quashed an assessment addition of ₹46.87 lakhs, based on a partner's seized documents, for bypassing the Section 153C procedure. Section 153C dictates that assessment based on seized documents belonging to a person other than the one searched requires specific procedural steps. The tribunal found that the Assessing Officer failed to follow these mandatory procedures before making the addition, rendering the assessment invalid. This ruling reinforces the importance of strict adherence to prescribed procedures in search and seizure assessments, protecting taxpayers from arbitrary additions.