Calcutta High Court: Section 153C Cannot Be Invoked Without Incriminating Material

The Calcutta High Court held that Section 153C of the Income Tax Act—governing assessments of persons other than the searched entity—cannot be invoked unless the material seized during a search is both incriminating and pertains to the assessee. The Court reiterated that mere recovery of documents is insufficient. The decision underscores strict procedural compliance, limiting arbitrary assessments and reinforcing taxpayer protections in search cases. It ensures revenue authorities justify every invocation of 153C with material that clearly indicates undisclosed income or financial wrongdoing.