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    <title>2023 (12) TMI 92 - ITAT MUMBAI</title>
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    <description>In an unabated section 153C assessment, an addition under section 68 for share premium could not be sustained where no incriminating material was found during search, and a statement alone was treated as insufficient without seized corroboration. The assessment was also vulnerable because recording of satisfaction by the Assessing Officer of the searched person is a mandatory jurisdictional for section 153C; on the record, that satisfaction note could not be established. The result was deletion of the addition and the section 153C proceedings were treated as void ab initio, leaving the appellate relief to the assessee undisturbed.</description>
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      <title>2023 (12) TMI 92 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=446408</link>
      <description>In an unabated section 153C assessment, an addition under section 68 for share premium could not be sustained where no incriminating material was found during search, and a statement alone was treated as insufficient without seized corroboration. The assessment was also vulnerable because recording of satisfaction by the Assessing Officer of the searched person is a mandatory jurisdictional for section 153C; on the record, that satisfaction note could not be established. The result was deletion of the addition and the section 153C proceedings were treated as void ab initio, leaving the appellate relief to the assessee undisturbed.</description>
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      <pubDate>Mon, 28 Aug 2023 00:00:00 +0530</pubDate>
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