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    <title>2026 (3) TMI 1233 - ITAT DELHI</title>
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    <description>Where the Assessing Officer has already assumed jurisdiction under section 153C and proceeded for the relevant assessment years, later recourse to sections 147/148 is impermissible because the Act does not contemplate parallel assessment proceedings; the reassessment is therefore invalid. On the deletion of the addition under section 69C, the challenge failed because the cited High Court decision was treated as not having clear finality, and the Revenue&#039;s reliance on it was considered misconceived. Since the reassessment itself was held bad in law, the merits of the addition became academic and were not separately adjudicated.</description>
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      <link>https://www.taxtmi.com/caselaws?id=788478</link>
      <description>Where the Assessing Officer has already assumed jurisdiction under section 153C and proceeded for the relevant assessment years, later recourse to sections 147/148 is impermissible because the Act does not contemplate parallel assessment proceedings; the reassessment is therefore invalid. On the deletion of the addition under section 69C, the challenge failed because the cited High Court decision was treated as not having clear finality, and the Revenue&#039;s reliance on it was considered misconceived. Since the reassessment itself was held bad in law, the merits of the addition became academic and were not separately adjudicated.</description>
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