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    <title>2017 (1) TMI 1148 - BOMBAY HIGH COURT</title>
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    <description>Reassessment under Section 148 of the Income-tax Act was invalid because the Assessing Officer did not independently form a reason to believe, on relevant material, that income had escaped assessment. The assessment for the year had already been completed under Section 143(3) read with Section 153A after search proceedings, and the on-money issue had been examined then; unsigned and undated third-party documents, which did not identify the assessee or the purchasers, could not support jurisdiction, and the Section 132(4A) presumption was inapplicable to material found in another person&#039;s search.</description>
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      <description>Reassessment under Section 148 of the Income-tax Act was invalid because the Assessing Officer did not independently form a reason to believe, on relevant material, that income had escaped assessment. The assessment for the year had already been completed under Section 143(3) read with Section 153A after search proceedings, and the on-money issue had been examined then; unsigned and undated third-party documents, which did not identify the assessee or the purchasers, could not support jurisdiction, and the Section 132(4A) presumption was inapplicable to material found in another person&#039;s search.</description>
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