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    <title>2025 (6) TMI 1529 - ITAT HYDERABAD</title>
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    <description>Section 153C jurisdiction arises only when the Assessing Officer records a clear, reasoned satisfaction that seized books, documents, or assets are incriminating and have a bearing on the other person&#039;s total income for the relevant year. Here, the recorded satisfaction referred to a joint development agreement and related papers, but did not establish a year-wise nexus between any seized material and undisclosed income. The agreement and refundable security were already disclosed in the assessee&#039;s books, balance sheet, cash book, and bank account, so they were not incriminating material by themselves. In the absence of the required linkage, initiation under section 153C was held invalid and the assessment was quashed.</description>
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    <pubDate>Thu, 24 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1529 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=773416</link>
      <description>Section 153C jurisdiction arises only when the Assessing Officer records a clear, reasoned satisfaction that seized books, documents, or assets are incriminating and have a bearing on the other person&#039;s total income for the relevant year. Here, the recorded satisfaction referred to a joint development agreement and related papers, but did not establish a year-wise nexus between any seized material and undisclosed income. The agreement and refundable security were already disclosed in the assessee&#039;s books, balance sheet, cash book, and bank account, so they were not incriminating material by themselves. In the absence of the required linkage, initiation under section 153C was held invalid and the assessment was quashed.</description>
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      <pubDate>Thu, 24 Apr 2025 00:00:00 +0530</pubDate>
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