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    <title>2025 (12) TMI 1815 - ITAT DELHI</title>
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    <description>Search-linked reassessment procedure was treated as the governing route where a search under section 132 had been initiated and the year fell within the covered period; the regular assessment under section 143(3) was held unsustainable and quashed because the special mechanism under section 148, with prior approval under section 148B, overrides the general scrutiny provision. On profit estimation, the use of a mean rate based on past results and comparables was rejected as arbitrary; estimation was required to rest on contemporaneous segmental trade data. The gross profit rate was therefore fixed at 6.96%, and the Revenue&#039;s higher estimate was declined.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467982</link>
      <description>Search-linked reassessment procedure was treated as the governing route where a search under section 132 had been initiated and the year fell within the covered period; the regular assessment under section 143(3) was held unsustainable and quashed because the special mechanism under section 148, with prior approval under section 148B, overrides the general scrutiny provision. On profit estimation, the use of a mean rate based on past results and comparables was rejected as arbitrary; estimation was required to rest on contemporaneous segmental trade data. The gross profit rate was therefore fixed at 6.96%, and the Revenue&#039;s higher estimate was declined.</description>
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