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    <title>2022 (2) TMI 808 - ITAT MUMBAI</title>
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    <description>Section 153C jurisdiction requires seized material specifically belonging to or pertaining to the assessee and having a live nexus with the relevant year; general group-level references and unlinked statements are insufficient, so the assessment was held invalid. Additions for undisclosed car parking receipts and on-money on flat sales could not stand where the material was not shown to be assessee-specific and the electronic evidence did not satisfy the required evidentiary standard, so those additions were deleted. The disallowance of set-off of brought forward losses under section 79 depended on unresolved shareholding facts, so the issue was remanded for fresh examination.</description>
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    <pubDate>Wed, 09 Feb 2022 00:00:00 +0530</pubDate>
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      <title>2022 (2) TMI 808 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=418557</link>
      <description>Section 153C jurisdiction requires seized material specifically belonging to or pertaining to the assessee and having a live nexus with the relevant year; general group-level references and unlinked statements are insufficient, so the assessment was held invalid. Additions for undisclosed car parking receipts and on-money on flat sales could not stand where the material was not shown to be assessee-specific and the electronic evidence did not satisfy the required evidentiary standard, so those additions were deleted. The disallowance of set-off of brought forward losses under section 79 depended on unresolved shareholding facts, so the issue was remanded for fresh examination.</description>
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