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ITAT held that the search assessment regime under section 153C is triggered by initiation of search in the case of the searched person, not by the later notice to the other person; because the search and handover of seized material occurred before 01/04/2021, the pre-amended law applied and the notice was valid. On merits, the addition based solely on seized pen drive data and Excel printouts failed because the electronic record was inadmissible for lack of valid section 65B compliance and no independent corroboration existed. The separate addition based on an unsigned third-party voucher was also deleted for want of supporting evidence and for internal inconsistency in the assessment order.
ITAT held that the search assessment regime under section 153C is triggered by initiation of search in the case of the searched person, not by the later notice to the other person; because the search and handover of seized material occurred before 01/04/2021, the pre-amended law applied and the notice was valid. On merits, the addition based solely on seized pen drive data and Excel printouts failed because the electronic record was inadmissible for lack of valid section 65B compliance and no independent corroboration existed. The separate addition based on an unsigned third-party voucher was also deleted for want of supporting evidence and for internal inconsistency in the assessment order.
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