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    <title>2024 (8) TMI 502 - MADRAS HIGH COURT</title>
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    <description>Section 153C proceedings were upheld against challenges based on limitation, jurisdiction and evidence: the Court held that satisfaction may be recorded at the time of, during, or immediately after completion of the searched person&#039;s assessment, that no separate statutory time limit exists for such recording, and that a single satisfaction note is sufficient where the same Assessing Officer acts for both persons. It also held that electronic material can be relied on in quasi-judicial tax proceedings and that Evidence Act objections, including Section 65B and denial of cross-examination, did not vitiate the assessments. By contrast, overlapping additions of the same unexplained income in the hands of two directors required reconsideration, and those assessments were remanded for fresh orders.</description>
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      <link>https://www.taxtmi.com/caselaws?id=756798</link>
      <description>Section 153C proceedings were upheld against challenges based on limitation, jurisdiction and evidence: the Court held that satisfaction may be recorded at the time of, during, or immediately after completion of the searched person&#039;s assessment, that no separate statutory time limit exists for such recording, and that a single satisfaction note is sufficient where the same Assessing Officer acts for both persons. It also held that electronic material can be relied on in quasi-judicial tax proceedings and that Evidence Act objections, including Section 65B and denial of cross-examination, did not vitiate the assessments. By contrast, overlapping additions of the same unexplained income in the hands of two directors required reconsideration, and those assessments were remanded for fresh orders.</description>
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