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    <title>2026 (1) TMI 473 - KARNATAKA HIGH COURT</title>
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    <description>Section 153C applies only to a true &quot;other person&quot; when seized material from one person&#039;s search is transferred for assessment of another; where the search was conducted in the petitioner&#039;s own premises and the satisfaction note and panchanama showed the petitioner was the searched person, initiation under section 153C lacked jurisdiction. The assessment order and consequential notices were also found time-barred because the order was not dispatched within the limitation period, and an order affecting civil consequences is effective only when issued so as to pass beyond the authority&#039;s control within time. The assessment, demand, computation and penalty proceedings were therefore unsustainable.</description>
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    <pubDate>Thu, 11 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 473 - KARNATAKA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=784717</link>
      <description>Section 153C applies only to a true &quot;other person&quot; when seized material from one person&#039;s search is transferred for assessment of another; where the search was conducted in the petitioner&#039;s own premises and the satisfaction note and panchanama showed the petitioner was the searched person, initiation under section 153C lacked jurisdiction. The assessment order and consequential notices were also found time-barred because the order was not dispatched within the limitation period, and an order affecting civil consequences is effective only when issued so as to pass beyond the authority&#039;s control within time. The assessment, demand, computation and penalty proceedings were therefore unsustainable.</description>
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      <pubDate>Thu, 11 Dec 2025 00:00:00 +0530</pubDate>
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