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    <title>2026 (1) TMI 1104 - ITAT MUMBAI</title>
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    <description>Pecuniary jurisdiction has no application to search assessments because such assessments are not assigned by pecuniary limits; therefore jurisdictional objections to a search assessment fail. Where incriminating material is found during search, additions based on that material are sustain able; thus part of assessment under section 153A was upheld. Treating gross sale proceeds as taxable additions is impermissible when those receipts embed gross profit; only the profit element may be added, and the appellate finding to that effect is sustained. Provisions for interest on delayed service tax payments are compensatory and allowable where paid or written back. Bogus purchases require the assessee to discharge the primary onus of genuineness; absent evidence, additions stand. Transfer pricing: an unreliable single foreign comparable fails CUP scrutiny and ALP; domestic SBI PLR plus risk adjustment upheld.</description>
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    <pubDate>Mon, 24 Nov 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=785348</link>
      <description>Pecuniary jurisdiction has no application to search assessments because such assessments are not assigned by pecuniary limits; therefore jurisdictional objections to a search assessment fail. Where incriminating material is found during search, additions based on that material are sustain able; thus part of assessment under section 153A was upheld. Treating gross sale proceeds as taxable additions is impermissible when those receipts embed gross profit; only the profit element may be added, and the appellate finding to that effect is sustained. Provisions for interest on delayed service tax payments are compensatory and allowable where paid or written back. Bogus purchases require the assessee to discharge the primary onus of genuineness; absent evidence, additions stand. Transfer pricing: an unreliable single foreign comparable fails CUP scrutiny and ALP; domestic SBI PLR plus risk adjustment upheld.</description>
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