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    <title>2026 (2) TMI 798 - ITAT PUNE</title>
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    <description>Reassessment initiated solely on incriminating material seized from a third party was invalid because the special search linked procedure must be invoked where reopening relies exclusively on third party search material; reopening under the general provision was quashed. Additions founded on a single notation in seized loose papers and extrapolated cash receipts lacked independent corroboration from books, registered sale deeds or identification by the searched person; such conjectural extrapolation cannot sustain additions and were deleted. On combined legal and factual findings, jurisdictional impropriety vitiated the reassessment and uncorroborated substantive additions were disallowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786650</link>
      <description>Reassessment initiated solely on incriminating material seized from a third party was invalid because the special search linked procedure must be invoked where reopening relies exclusively on third party search material; reopening under the general provision was quashed. Additions founded on a single notation in seized loose papers and extrapolated cash receipts lacked independent corroboration from books, registered sale deeds or identification by the searched person; such conjectural extrapolation cannot sustain additions and were deleted. On combined legal and factual findings, jurisdictional impropriety vitiated the reassessment and uncorroborated substantive additions were disallowed.</description>
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