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    <title>2025 (12) TMI 355 - BOMBAY HIGH COURT</title>
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    <description>HC allowed the assessee&#039;s appeal and quashed the assessment u/s 153A. It held that no incriminating material was found during the search u/s 132 linking the assessee to the foreign bank accounts; the only basis was a &quot;base note&quot; obtained post-search and belonging to group entities. HSBC Bank (Suisse) confirmed in writing that the assessee had no connection with the accounts. As the original assessments were completed and the base note was not a search-recovered document, it could not constitute incriminating material for reassessment. Following binding SC and HC precedent, HC held that in the absence of incriminating material, no addition u/s 153A could be sustained.</description>
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      <title>2025 (12) TMI 355 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=782815</link>
      <description>HC allowed the assessee&#039;s appeal and quashed the assessment u/s 153A. It held that no incriminating material was found during the search u/s 132 linking the assessee to the foreign bank accounts; the only basis was a &quot;base note&quot; obtained post-search and belonging to group entities. HSBC Bank (Suisse) confirmed in writing that the assessee had no connection with the accounts. As the original assessments were completed and the base note was not a search-recovered document, it could not constitute incriminating material for reassessment. Following binding SC and HC precedent, HC held that in the absence of incriminating material, no addition u/s 153A could be sustained.</description>
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      <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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