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    <title>Third-party search material requires section 153C, and retracted survey statements need corroboration for additions.</title>
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    <description>Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue&#039;s challenge and sustained the finding that the additions were unsustainable.</description>
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    <pubDate>Fri, 17 Apr 2026 08:21:23 +0530</pubDate>
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      <title>Third-party search material requires section 153C, and retracted survey statements need corroboration for additions.</title>
      <link>https://www.taxtmi.com/highlights?id=98877</link>
      <description>Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue&#039;s challenge and sustained the finding that the additions were unsustainable.</description>
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      <pubDate>Fri, 17 Apr 2026 08:21:23 +0530</pubDate>
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