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ITAT adjudicated a complex tax assessment case involving search and seizure proceedings under Section 153A. The tribunal addressed jurisdictional issues regarding unexplained cash deposits and the interpretation of 'other material' during assessment. After divergent opinions from bench members, a third member was consulted. The final outcome involves partially allowing appeals from both the department and assessee, with specific directions to restore matters to CIT(A) for merit-based examination of incriminating and other materials found during search proceedings. The decision emphasizes the nuanced interplay between Sections 153A, 153C, and 147, highlighting the tribunal's careful approach to reassessment and multiple assessment limitations in search-related tax proceedings.
ITAT adjudicated a complex tax assessment case involving search and seizure proceedings under Section 153A. The tribunal addressed jurisdictional issues regarding unexplained cash deposits and the interpretation of 'other material' during assessment. After divergent opinions from bench members, a third member was consulted. The final outcome involves partially allowing appeals from both the department and assessee, with specific directions to restore matters to CIT(A) for merit-based examination of incriminating and other materials found during search proceedings. The decision emphasizes the nuanced interplay between Sections 153A, 153C, and 147, highlighting the tribunal's careful approach to reassessment and multiple assessment limitations in search-related tax proceedings.
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