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    <title>2023 (2) TMI 1161 - ITAT PUNE</title>
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    <description>ITAT Pune held that an assessment and rectification communication issued without DIN and required order particulars, contrary to CBDT circulars, was invalid and could not be cured by later allotment of DIN; the assessment and rectification were quashed. On the addition issue, the Tribunal treated the seized paper as a dumb document in the absence of corroboration, accepted telescoping of the cash-based addition against explained cash, and sustained only the balance not linked to unaccounted jewellery. Admissions during search, without supporting evidence, were insufficient to justify the full addition, and the Revenue&#039;s cross appeal failed.</description>
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    <pubDate>Tue, 14 Feb 2023 00:00:00 +0530</pubDate>
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      <title>2023 (2) TMI 1161 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=308767</link>
      <description>ITAT Pune held that an assessment and rectification communication issued without DIN and required order particulars, contrary to CBDT circulars, was invalid and could not be cured by later allotment of DIN; the assessment and rectification were quashed. On the addition issue, the Tribunal treated the seized paper as a dumb document in the absence of corroboration, accepted telescoping of the cash-based addition against explained cash, and sustained only the balance not linked to unaccounted jewellery. Admissions during search, without supporting evidence, were insufficient to justify the full addition, and the Revenue&#039;s cross appeal failed.</description>
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