https://www.taxtmi.com/caselaws?id=441457 In search assessments, jurisdiction under sections 153C and 153A must rest on valid satisfaction and a year-wise nexus with seized material; transfer under section 127 was upheld, but notices for years lacking the required statutory basis were invalid. Retractions of search statements were accepted where the statements lacked corroboration and were inconsistent with surrounding facts, so they were not conclusive proof. Additions for under-reporting, bogus purchases and dummy-entity transactions failed for want of reliable evidence and quantification. Enhancement under section 69C based on unidentified electronic entries and the special audit material was rejected because the records were treated as incapable of attribution without proof of nexus to the assessee. The approval under section 153D was upheld, while rejection of the special audit reports was found unjustified. en-us Fri, 07 Jul 2023 00:00:00 +0530 Tue, 08 Aug 2023 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441457 In search assessments, jurisdiction under sections 153C and 153A must rest on valid satisfaction and a year-wise nexus with seized material; transfer under section 127 was upheld, but notices for years lacking the required statutory basis were invalid. Retractions of search statements were accepted where the statements lacked corroboration and were inconsistent with surrounding facts, so they were not conclusive proof. Additions for under-reporting, bogus purchases and dummy-entity transactions failed for want of reliable evidence and quantification. Enhancement under section 69C based on unidentified electronic entries and the special audit material was rejected because the records were treated as incapable of attribution without proof of nexus to the assessee. The approval under section 153D was upheld, while rejection of the special audit reports was found unjustified. Case-Laws Income Tax Fri, 07 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441457