Proceedings u/s 153C of Income Tax Act cannot be Initiated in Absence of Incriminating Material: Delhi HC

The Delhi High Court quashed income tax proceedings under Section 153C, ruling they cannot be initiated without incriminating material found during searches. Justice Manmohan held that mere reference to an assessee's name in another entity's seized documents doesn't justify 153C jurisdiction. The case involved survey findings against a builder that merely mentioned the petitioner's property purchase without any evidence of concealment. This reinforces the strict legal requirements for invoking extended assessment powers under search cases. The judgment protects taxpayers from fishing expeditions where no undisclosed income evidence actually exists. Authorities must now demonstrate concrete seized materials specifically indicating the assessee's tax evasion before issuing 153C notices.