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Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
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