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    <title>2025 (12) TMI 1513 - ITAT DELHI</title>
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    <description>Jurisdiction under s.153C was held invalid because the seized cash-transaction material related to AY 2016-17 and did not bear on determination of total income for AY 2015-16; applying SC law that incriminating material must pertain to the year in question, the notice for AY 2015-16 was quashed. Independently, AY 2015-16 was an unabated/completed year with no pending proceedings and no incriminating material for that year, so no addition could be made in s.153C/s.153A assessment, following SC precedent; the assessment was unsustainable. Further, a consolidated satisfaction note for multiple years violated the requirement of year-wise satisfaction, vitiating the proceedings. The Revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1513 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783973</link>
      <description>Jurisdiction under s.153C was held invalid because the seized cash-transaction material related to AY 2016-17 and did not bear on determination of total income for AY 2015-16; applying SC law that incriminating material must pertain to the year in question, the notice for AY 2015-16 was quashed. Independently, AY 2015-16 was an unabated/completed year with no pending proceedings and no incriminating material for that year, so no addition could be made in s.153C/s.153A assessment, following SC precedent; the assessment was unsustainable. Further, a consolidated satisfaction note for multiple years violated the requirement of year-wise satisfaction, vitiating the proceedings. The Revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Fri, 19 Dec 2025 00:00:00 +0530</pubDate>
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