Assessment was held time-barred where clause (xii) of...

Assessment was held time-barred where clause (xii) of Explanation 1 to section 153 operated only as an exclusion of the period during which seized material was unavailable within the running limitation period, not as an enlargement of the total time for assessment; the order passed after the outer date was quashed. On merits, additions based on third-party seized cash entries were deleted because the material came from other entities, the witness retracted the earlier statement, and no independent corroboration connected the assessee to any cash receipt. Digital entries from a pen drive were inadmissible without a valid section 65B certificate, and presumptions under sections 132(4A) and 292C did not apply against the assessee. Section 56(2)(x) failed because actual receipt without consideration was not proved.

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