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    <title>2021 (2) TMI 654 - ITAT INDORE</title>
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    <description>A pure legal ground challenging the validity of the assessment, where the relevant facts were already on record, could be admitted at the appellate stage because it went to the root of jurisdiction. In search assessments under section 153A read with section 143(3), additions cannot stand unless they are supported by incriminating material found during the search. As no seized material was found relating to the disputed agricultural income, the additions were held unsustainable and the assessment orders were set aside.</description>
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      <description>A pure legal ground challenging the validity of the assessment, where the relevant facts were already on record, could be admitted at the appellate stage because it went to the root of jurisdiction. In search assessments under section 153A read with section 143(3), additions cannot stand unless they are supported by incriminating material found during the search. As no seized material was found relating to the disputed agricultural income, the additions were held unsustainable and the assessment orders were set aside.</description>
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