In the result, the appeals of the assessee are allowed
Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
Section 153C, as settled by the Hon’ble Supreme Court: Satisfaction of the Assessing Officer should be based on cogent material and should not be arrived at in a casual manner. It is submitted that Section 132(4A) (i) clearly stipulates that when inter alia any document is found in the possession or control of any person in the course