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    <title>2025 (12) TMI 839 - ITAT MUMBAI</title>
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    <description>ITAT set aside additions made u/s 153C in respect of alleged bogus purchases, unaccounted income and estimated commission on circular transactions within a group. Relying on a prior coordinate bench ruling arising from the same search, ITAT held there was no seized document, statement, or identified payer evidencing receipt of cash or other unaccounted consideration, nor any material showing that disclosed margins were understated. It ruled that assessments u/s 153C cannot become roving enquiries and must be based on incriminating material specific to the assessee and year. Consequently, the estimated additions on purchases/sales were deleted for all years, rendering the jurisdictional challenge under s.153C academic.</description>
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      <title>2025 (12) TMI 839 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783299</link>
      <description>ITAT set aside additions made u/s 153C in respect of alleged bogus purchases, unaccounted income and estimated commission on circular transactions within a group. Relying on a prior coordinate bench ruling arising from the same search, ITAT held there was no seized document, statement, or identified payer evidencing receipt of cash or other unaccounted consideration, nor any material showing that disclosed margins were understated. It ruled that assessments u/s 153C cannot become roving enquiries and must be based on incriminating material specific to the assessee and year. Consequently, the estimated additions on purchases/sales were deleted for all years, rendering the jurisdictional challenge under s.153C academic.</description>
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      <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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