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    <title>2025 (4) TMI 594 - ITAT MUMBAI</title>
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    <description>A search during the period available for regular assessment did not require recourse to section 148, so the challenge to the assessment notice failed. Additions based on images, loose sheets, sticky notes and retracted third-party statements were unsustainable because the material was uncorroborated, lacked reliable linkage to the assessee, and was treated as a dumb document. Section 69A was held inapplicable absent actual ownership of money or other assets found, and section 69C could not survive without credible proof of the underlying expenditure. The disputed additions were deleted and the relief granted by the first appellate authority was substantially sustained.</description>
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      <description>A search during the period available for regular assessment did not require recourse to section 148, so the challenge to the assessment notice failed. Additions based on images, loose sheets, sticky notes and retracted third-party statements were unsustainable because the material was uncorroborated, lacked reliable linkage to the assessee, and was treated as a dumb document. Section 69A was held inapplicable absent actual ownership of money or other assets found, and section 69C could not survive without credible proof of the underlying expenditure. The disputed additions were deleted and the relief granted by the first appellate authority was substantially sustained.</description>
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