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    <title>2026 (3) TMI 1555 - ITAT DELHI</title>
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    <description>Reopening under Section 147 was held inapplicable where the assessment was initiated on information arising from a search in another case and the matter should have been considered, if at all, under the search-related special provision of Section 153C. The reassessment notice and the assessment made pursuant to it were treated as without jurisdiction and void. As the jurisdictional defect was decisive, the merits of the disallowance were not examined and were left open as academic.</description>
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      <description>Reopening under Section 147 was held inapplicable where the assessment was initiated on information arising from a search in another case and the matter should have been considered, if at all, under the search-related special provision of Section 153C. The reassessment notice and the assessment made pursuant to it were treated as without jurisdiction and void. As the jurisdictional defect was decisive, the merits of the disallowance were not examined and were left open as academic.</description>
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