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    <title>2022 (1) TMI 623 - ITAT JAIPUR</title>
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    <description>Third-party search material does not automatically require proceedings under section 153C; that route applies only where the searched person&#039;s Assessing Officer records the requisite satisfaction and hands over seized material to the other person&#039;s Assessing Officer. On the facts noted, only information extracts were received, so reopening under section 147 was not invalid on that ground alone. Additions based on pen drive entries and third-party statements failed because the material was vague, coded and uncorroborated, no independent enquiry or payment trail was established, and effective cross-examination was denied. The Tribunal treated such electronic material as insufficient to sustain additions under sections 68 and 69 without clear nexus and corroboration.</description>
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    <pubDate>Fri, 22 Oct 2021 00:00:00 +0530</pubDate>
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      <title>2022 (1) TMI 623 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=417158</link>
      <description>Third-party search material does not automatically require proceedings under section 153C; that route applies only where the searched person&#039;s Assessing Officer records the requisite satisfaction and hands over seized material to the other person&#039;s Assessing Officer. On the facts noted, only information extracts were received, so reopening under section 147 was not invalid on that ground alone. Additions based on pen drive entries and third-party statements failed because the material was vague, coded and uncorroborated, no independent enquiry or payment trail was established, and effective cross-examination was denied. The Tribunal treated such electronic material as insufficient to sustain additions under sections 68 and 69 without clear nexus and corroboration.</description>
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      <pubDate>Fri, 22 Oct 2021 00:00:00 +0530</pubDate>
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