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    <title>2025 (9) TMI 784 - ITAT BANGALORE</title>
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    <description>Jurisdiction under section 153C depends on incriminating material relating to the assessee, a valid year-wise satisfaction note, and compliance with mandatory notice requirements under section 143(2). On the facts described, the seized documents were already disclosed, no fresh incriminating material was shown, the satisfaction note was defective, and no valid post-return notice was issued, so the assessment was held void ab initio. The additions for capital gains under joint development agreements, sale proceeds of flats, refundable deposit, and related disallowance were also deleted because the income had already been offered, the pre-section 45(5A) agreements were outside that deeming rule, and duplicative taxation was impermissible.</description>
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      <title>2025 (9) TMI 784 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=778295</link>
      <description>Jurisdiction under section 153C depends on incriminating material relating to the assessee, a valid year-wise satisfaction note, and compliance with mandatory notice requirements under section 143(2). On the facts described, the seized documents were already disclosed, no fresh incriminating material was shown, the satisfaction note was defective, and no valid post-return notice was issued, so the assessment was held void ab initio. The additions for capital gains under joint development agreements, sale proceeds of flats, refundable deposit, and related disallowance were also deleted because the income had already been offered, the pre-section 45(5A) agreements were outside that deeming rule, and duplicative taxation was impermissible.</description>
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