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    <title>2024 (12) TMI 240 - ITAT CHENNAI</title>
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    <description>ITAT Chennai held that AO lacked jurisdiction under Section 153C to issue notice to a third party not searched, as satisfaction note failed to meet legal requirements with no incriminating material pertaining to appellant. Assessment orders for AYs 2014-15 and 2016-17 were declared null and void. Following Supreme Court precedent in Abhisar Buildwell, tribunal ruled that additions under Section 153C in unabated assessments are only permissible when based on incriminating material found during search. Since additions under Section 56(2)(vii)(b) lacked supporting incriminating evidence from search, AO was directed to delete all impugned additions.</description>
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    <pubDate>Fri, 27 Sep 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 240 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=762660</link>
      <description>ITAT Chennai held that AO lacked jurisdiction under Section 153C to issue notice to a third party not searched, as satisfaction note failed to meet legal requirements with no incriminating material pertaining to appellant. Assessment orders for AYs 2014-15 and 2016-17 were declared null and void. Following Supreme Court precedent in Abhisar Buildwell, tribunal ruled that additions under Section 153C in unabated assessments are only permissible when based on incriminating material found during search. Since additions under Section 56(2)(vii)(b) lacked supporting incriminating evidence from search, AO was directed to delete all impugned additions.</description>
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      <pubDate>Fri, 27 Sep 2024 00:00:00 +0530</pubDate>
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