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    <title>Invocation of jurisdiction under section 153C based on third-party seized documents held invalid; assessment quashed</title>
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    <description>Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as &quot;dumb documents&quot; absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO&#039;s satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.</description>
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    <pubDate>Mon, 02 Feb 2026 08:20:23 +0530</pubDate>
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      <title>Invocation of jurisdiction under section 153C based on third-party seized documents held invalid; assessment quashed</title>
      <link>https://www.taxtmi.com/highlights?id=96528</link>
      <description>Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as &quot;dumb documents&quot; absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO&#039;s satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.</description>
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      <pubDate>Mon, 02 Feb 2026 08:20:23 +0530</pubDate>
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