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    <title>2026 (1) TMI 244 - ITAT DELHI</title>
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    <description>The Tribunal held that the impugned assessment for AY 2020-21 was validly framed under s.153A r.w.s. 143(3) because, besides the search triggering the s.153A notice, a subsequent authorization brought the year within the six-year block; the assessee&#039;s objection to treatment as a &quot;regular&quot; s.143(3) assessment was rejected. It further held that a transfer of jurisdiction under s.127(2) could not be assailed before the Tribunal and, in any event, no material showed the order to be legally unsustainable; the challenge failed. Additions under s.69A r.w.s. 115BBE founded on material from a third party&#039;s premises were deleted, as such action required s.153C proceedings. However, cash found/seized at the assessee&#039;s premises was sustained by applying the s.292C presumption and lack of satisfactory explanation.</description>
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    <pubDate>Wed, 31 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 244 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784488</link>
      <description>The Tribunal held that the impugned assessment for AY 2020-21 was validly framed under s.153A r.w.s. 143(3) because, besides the search triggering the s.153A notice, a subsequent authorization brought the year within the six-year block; the assessee&#039;s objection to treatment as a &quot;regular&quot; s.143(3) assessment was rejected. It further held that a transfer of jurisdiction under s.127(2) could not be assailed before the Tribunal and, in any event, no material showed the order to be legally unsustainable; the challenge failed. Additions under s.69A r.w.s. 115BBE founded on material from a third party&#039;s premises were deleted, as such action required s.153C proceedings. However, cash found/seized at the assessee&#039;s premises was sustained by applying the s.292C presumption and lack of satisfactory explanation.</description>
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      <pubDate>Wed, 31 Dec 2025 00:00:00 +0530</pubDate>
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