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    <title>2025 (12) TMI 728 - ITAT PATNA</title>
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    <description>ITAT held that in an unabated assessment year, additions under s.153A are permissible only on the basis of incriminating material seized during search. Although cash intercepted and requisitioned under s.132A was deposited in the PDA account and ownership thereof was accepted by the assessee, the AO&#039;s disallowances were based solely on examination of regular books and records, without any seized incriminating material. Applying the settled legal position limiting s.153A jurisdiction in unabated years, the Tribunal found the additions unsustainable in law and allowed the assessee&#039;s appeal.</description>
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    <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 728 - ITAT PATNA</title>
      <link>https://www.taxtmi.com/caselaws?id=783188</link>
      <description>ITAT held that in an unabated assessment year, additions under s.153A are permissible only on the basis of incriminating material seized during search. Although cash intercepted and requisitioned under s.132A was deposited in the PDA account and ownership thereof was accepted by the assessee, the AO&#039;s disallowances were based solely on examination of regular books and records, without any seized incriminating material. Applying the settled legal position limiting s.153A jurisdiction in unabated years, the Tribunal found the additions unsustainable in law and allowed the assessee&#039;s appeal.</description>
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      <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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