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    <title>2025 (2) TMI 1354 - ITAT CHENNAI</title>
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    <description>Assumption of jurisdiction under search-and-seizure was challenged where the assessing officer recorded a satisfaction note and made additions based on loose papers seized from a third party and on third-party statements. The satisfaction note was held legally infirm because there was no document-wise correlation showing the seized material incriminated the assessee, the loose papers lacked evidentiary character as books of account, and the relied statements were uncorroborated, biased or discredited. Failure to furnish relied statements and opportunity for cross-examination compounded the defect. Consequently, the additions founded on that satisfaction note and the impugned statements were invalidated and the revenue appeal dismissed.</description>
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      <title>2025 (2) TMI 1354 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=466158</link>
      <description>Assumption of jurisdiction under search-and-seizure was challenged where the assessing officer recorded a satisfaction note and made additions based on loose papers seized from a third party and on third-party statements. The satisfaction note was held legally infirm because there was no document-wise correlation showing the seized material incriminated the assessee, the loose papers lacked evidentiary character as books of account, and the relied statements were uncorroborated, biased or discredited. Failure to furnish relied statements and opportunity for cross-examination compounded the defect. Consequently, the additions founded on that satisfaction note and the impugned statements were invalidated and the revenue appeal dismissed.</description>
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