Sec. 153C of the Income-tax Act, 1961 - Search and seizure - The assessment was finalised under section 143(3) r.w.s 153C of the I.T Act. Consequent to the search action under section 132 of the I.T Act determining the total income at Rs. 11,65,31,847/-. An addition was made amounting to Rs. 11,65,91,847/-, on the basis of the document being 'saudachithi'. The said document was recovered from the bank locker of one Shri Kirit M. Shah and was seized. The sale price reflected is Rs. 16,17,91,847/- whereas, the sale consideration shown in the registered sale deed was only to the tune of Rs. 4,52,60,000/-. Thus, the difference of Rs. 11,65,31,847/- was added to the total income as unexplained expenditure under section 69C of the Act. CIT(A) confirmed the order of AO. Tribunal allowed the appeal of the assessee holding the assessment illegal and void ab initio. Thus, revenue filed Tax Appeal under section 260 the Act. High Court dismissed the revenue’s appeal holding that ”where the satisfaction by the AO of the person searched and other person is not found recorded, the Department should not press that matter in Appeal. Thus, keeping in view rival submissions in light of judicial pronouncements in case of M/s Calcutta Knitwear's (Civil Appeal No. 3958 of 2014 dated 12-3-2014) and circular No. 24/2015 dated 31-12-2015, issued by the CBDT, the assessment in the assessee case for the assessment year under consideration is held as illegal and void ab initio". SLP of revenue also dismissed. - PR. CIT V/s MUNISUVRAT CORPORATION - [2020] 272 TAXMAN 181 (SC)