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    <title>2022 (12) TMI 639 - ITAT MUMBAI</title>
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    <description>In a search assessment under section 153C, jurisdiction requires incriminating material specifically relatable to the assessee and the relevant assessment year; absent such assessee-specific material, the assumption of jurisdiction was unsustainable and the challenge succeeded. On the same footing, additions treating capital gains as business income and additions for alleged car parking receipts and on-money from flats could not survive because no incriminating material was found for the assessee, and the assessment year was treated as concluded. The principal additions were therefore deleted, while the remaining issues did not survive independently.</description>
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      <description>In a search assessment under section 153C, jurisdiction requires incriminating material specifically relatable to the assessee and the relevant assessment year; absent such assessee-specific material, the assumption of jurisdiction was unsustainable and the challenge succeeded. On the same footing, additions treating capital gains as business income and additions for alleged car parking receipts and on-money from flats could not survive because no incriminating material was found for the assessee, and the assessment year was treated as concluded. The principal additions were therefore deleted, while the remaining issues did not survive independently.</description>
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