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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 require the assessment block to be computed from the date seized material reaches that person&#039;s jurisdictional Assessing Officer. Jurisdiction must rest on year-specific satisfaction linking seized material to each relevant year; consolidated satisfaction notes are insufficient. For assessments beyond six years, seized material must reveal escaped income represented by a qualifying undisclosed asset, and additions based solely on liabilities such as loans, advances or share capital do not meet that condition. Approval under Section 153D requires independent application of mind and cannot be a same-day mechanical formality. Section 68 applies only to credits recorded in the relevant year and does not support repeat taxation of amounts already disclosed and taxed.</description>
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      <description>Section 153C proceedings against a non-searched person require the assessment block to be computed from the date seized material reaches that person&#039;s jurisdictional Assessing Officer. Jurisdiction must rest on year-specific satisfaction linking seized material to each relevant year; consolidated satisfaction notes are insufficient. For assessments beyond six years, seized material must reveal escaped income represented by a qualifying undisclosed asset, and additions based solely on liabilities such as loans, advances or share capital do not meet that condition. Approval under Section 153D requires independent application of mind and cannot be a same-day mechanical formality. Section 68 applies only to credits recorded in the relevant year and does not support repeat taxation of amounts already disclosed and taxed.</description>
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