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    <title>2018 (1) TMI 711 - ITAT AHMEDABAD</title>
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    <description>Seized notebook entries and related statements were treated as tangible material linking the assessees to unaccounted receipts and expenditure, so reassessment under sections 147 and 148 was sustained and the special procedure under section 153C was held inapplicable because the material did not belong to the firm in the required sense. On the merits, partner admissions and the partnership deed supported taxing income in the firm&#039;s hands, while co-ownership additions were upheld on preponderance of probability from search material. Protective additions were maintained where substantive additions already existed in related hands, and certain receipts were shifted to the correct assessment year, with the additions largely sustained overall.</description>
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      <title>2018 (1) TMI 711 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=353975</link>
      <description>Seized notebook entries and related statements were treated as tangible material linking the assessees to unaccounted receipts and expenditure, so reassessment under sections 147 and 148 was sustained and the special procedure under section 153C was held inapplicable because the material did not belong to the firm in the required sense. On the merits, partner admissions and the partnership deed supported taxing income in the firm&#039;s hands, while co-ownership additions were upheld on preponderance of probability from search material. Protective additions were maintained where substantive additions already existed in related hands, and certain receipts were shifted to the correct assessment year, with the additions largely sustained overall.</description>
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