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    <title>2025 (1) TMI 1407 - ITAT DELHI</title>
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    <description>ITAT Delhi held that assessment under section 143(3) was void ab initio when made based on materials seized during search operations. The assessee contended that since assessment was based on materials found during Hans Group search on 06.01.2021, including WhatsApp chats from seized mobile phone, it should have been made under section 153C instead of regular assessment under section 143(3). ITAT agreed, noting that AO had recorded satisfaction note under section 153C but incorrectly proceeded under section 143(3). The assessment was quashed as not permissible under law, and assessee&#039;s additional ground was allowed.</description>
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    <pubDate>Tue, 28 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 1407 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=765342</link>
      <description>ITAT Delhi held that assessment under section 143(3) was void ab initio when made based on materials seized during search operations. The assessee contended that since assessment was based on materials found during Hans Group search on 06.01.2021, including WhatsApp chats from seized mobile phone, it should have been made under section 153C instead of regular assessment under section 143(3). ITAT agreed, noting that AO had recorded satisfaction note under section 153C but incorrectly proceeded under section 143(3). The assessment was quashed as not permissible under law, and assessee&#039;s additional ground was allowed.</description>
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      <pubDate>Tue, 28 Jan 2025 00:00:00 +0530</pubDate>
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