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    <title>2022 (6) TMI 256 - ITAT MUMBAI</title>
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    <description>The Tribunal held that proceedings initiated under Section 147 were void ab initio as they should have been conducted under Section 153C, based on material found during a search. The reassessment orders for the assessment years 2010-11 and 2011-12 were quashed, and the appeals by the assessee were allowed due to procedural invalidity. Penalty proceedings under Sections 271D and 271E were not specifically addressed as they were deemed invalid along with the assessment proceedings.</description>
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      <description>The Tribunal held that proceedings initiated under Section 147 were void ab initio as they should have been conducted under Section 153C, based on material found during a search. The reassessment orders for the assessment years 2010-11 and 2011-12 were quashed, and the appeals by the assessee were allowed due to procedural invalidity. Penalty proceedings under Sections 271D and 271E were not specifically addressed as they were deemed invalid along with the assessment proceedings.</description>
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