Notice U/S 153C Income Tax Act Can Be Issued Only If Incriminating Material Has 'Bearing On Total Income' Of Non-Searched Assessee: Delhi HC

The Delhi High Court has clarified that a notice under Section 153C of the Income Tax Act can be issued only if "incriminating material has a bearing on the total income of the non-searched assessee." This means that while a direct link between the searched entity and the non-searched entity is not mandatory, the seized documents or articles must demonstrably relate to or pertain to the income of the third party and impact their total income. This ruling provides a safeguard against arbitrary invocation of Section 153C, ensuring that the initiation of proceedings against a non-searched person is based on relevant incriminating evidence.