https://www.taxtmi.com/caselaws?id=467533 Special jurisdiction against a third person requires seized material that is genuinely incriminating and directly linked to the relevant assessment year; where the satisfaction note relies only on material already with the department or disclosed earlier, the notice and assessment are invalid. On merits, an addition as unexplained money cannot stand when bank statements and supporting records show the receipts were loans or bid refunds later repaid, and the enquiry has not examined the creditors or their accounts. Consequential interest becomes academic once the primary assessment is set aside. The tribunal therefore upheld deletion of the addition and treated the related interest issue as consequential. en-us Tue, 18 Feb 2025 00:00:00 +0530 Mon, 23 Mar 2026 20:37:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467533 Special jurisdiction against a third person requires seized material that is genuinely incriminating and directly linked to the relevant assessment year; where the satisfaction note relies only on material already with the department or disclosed earlier, the notice and assessment are invalid. On merits, an addition as unexplained money cannot stand when bank statements and supporting records show the receipts were loans or bid refunds later repaid, and the enquiry has not examined the creditors or their accounts. Consequential interest becomes academic once the primary assessment is set aside. The tribunal therefore upheld deletion of the addition and treated the related interest issue as consequential. Case-Laws Income Tax Tue, 18 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467533