https://www.taxtmi.com/caselaws?id=466184 Assumption of jurisdiction under s.153C was assessed against the limitation period, with the date of receipt of seized material by the non-searched person determining time bar; consequence: assessments for the specified years were found outside the limitation period and thus barred. The validity of the satisfaction note was challenged as vague and non-descriptive, lacking attribution of incriminating material to particular assessment years, and therefore did not support assumption of jurisdiction under s.153C; consequence: jurisdictional foundation was invalidated. Additions treating share capital and share premium as unexplained were rendered moot because the underpinning assessments were non-maintainable. en-us Wed, 12 Feb 2025 00:00:00 +0530 Wed, 28 Jan 2026 13:57:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466184 Assumption of jurisdiction under s.153C was assessed against the limitation period, with the date of receipt of seized material by the non-searched person determining time bar; consequence: assessments for the specified years were found outside the limitation period and thus barred. The validity of the satisfaction note was challenged as vague and non-descriptive, lacking attribution of incriminating material to particular assessment years, and therefore did not support assumption of jurisdiction under s.153C; consequence: jurisdictional foundation was invalidated. Additions treating share capital and share premium as unexplained were rendered moot because the underpinning assessments were non-maintainable. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466184