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    <title>2025 (1) TMI 378 - ITAT NAGPUR</title>
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    <description>Section 153C proceedings against a non-searched person are described as requiring the block period to be computed from the date seized material reaches that person&#039;s jurisdictional Assessing Officer, which placed only the later year within the extended period. The notes explain that jurisdiction must rest on year-specific satisfaction correlating seized material to each assessment year, and that consolidated satisfaction notes are inadequate. They further state that invocation of the extended period beyond six years requires seized material showing escaped income represented in a qualifying undisclosed asset; additions based on liabilities such as loans or share capital do not meet that condition. The text also identifies mechanical same-day approval under Section 153D and Section 68 additions without fresh credits, or on already disclosed amounts, as unsustainable.</description>
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    <pubDate>Thu, 26 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 378 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=764316</link>
      <description>Section 153C proceedings against a non-searched person are described as requiring the block period to be computed from the date seized material reaches that person&#039;s jurisdictional Assessing Officer, which placed only the later year within the extended period. The notes explain that jurisdiction must rest on year-specific satisfaction correlating seized material to each assessment year, and that consolidated satisfaction notes are inadequate. They further state that invocation of the extended period beyond six years requires seized material showing escaped income represented in a qualifying undisclosed asset; additions based on liabilities such as loans or share capital do not meet that condition. The text also identifies mechanical same-day approval under Section 153D and Section 68 additions without fresh credits, or on already disclosed amounts, as unsustainable.</description>
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      <pubDate>Thu, 26 Dec 2024 00:00:00 +0530</pubDate>
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