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    <title>2025 (12) TMI 344 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed the assessee&#039;s appeals and quashed the assessments framed u/s 153A. It held that the additions were made de hors any incriminating material found during the search, being based solely on a third-party statement, which is impermissible for concluded assessments in search proceedings. The Tribunal further held that, even assuming the statement could be relied on, the proper provision would be s.153C and not s.153A. Additionally, the approval u/s 153D was found to be ritualistic and non-speaking, covering multiple years and assessees in a single sanction without evidence of due application of mind, thereby vitiating the assessments.</description>
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      <title>2025 (12) TMI 344 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782804</link>
      <description>ITAT Delhi allowed the assessee&#039;s appeals and quashed the assessments framed u/s 153A. It held that the additions were made de hors any incriminating material found during the search, being based solely on a third-party statement, which is impermissible for concluded assessments in search proceedings. The Tribunal further held that, even assuming the statement could be relied on, the proper provision would be s.153C and not s.153A. Additionally, the approval u/s 153D was found to be ritualistic and non-speaking, covering multiple years and assessees in a single sanction without evidence of due application of mind, thereby vitiating the assessments.</description>
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