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    <title>2026 (2) TMI 755 - ITAT DELHI</title>
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    <description>For an unabated assessment year under the Income-tax law the Tribunal held that seized third party documents and statements recorded under search provisions qualify as incriminating material only if they directly indicate undisclosed income or assets and are corroborated by other reliable evidence; absent such direct link and corroboration, additions under the search based assessment are invalid, and the assessment was therefore set aside. Separately, an additional ground introduced before the Tribunal challenging mechanical approval was rejected under appellate Rule 27 because the issue and its factual matrix were not raised or decided at the earlier appellate stage and could not be newly admitted.</description>
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      <title>2026 (2) TMI 755 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=786607</link>
      <description>For an unabated assessment year under the Income-tax law the Tribunal held that seized third party documents and statements recorded under search provisions qualify as incriminating material only if they directly indicate undisclosed income or assets and are corroborated by other reliable evidence; absent such direct link and corroboration, additions under the search based assessment are invalid, and the assessment was therefore set aside. Separately, an additional ground introduced before the Tribunal challenging mechanical approval was rejected under appellate Rule 27 because the issue and its factual matrix were not raised or decided at the earlier appellate stage and could not be newly admitted.</description>
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