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    <title>2026 (5) TMI 458 - ITAT DELHI</title>
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    <description>Section 153C proceedings must be initiated within the applicable limitation period and on the basis of incriminating material that is clearly linked to a specific assessment year. Here, the notices were issued about 15 months after completion of the searched person&#039;s assessment, beyond the period recognised in binding precedent, and the COVID-19 relaxation did not cure the delay, so the notices were time barred and invalid. The satisfaction note was also defective because it relied on an undated, unsigned loose sheet, did not clearly identify the relevant year or its impact on total income, and reflected borrowed rather than independent satisfaction. The assessments were quashed.</description>
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    <pubDate>Wed, 29 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 458 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791256</link>
      <description>Section 153C proceedings must be initiated within the applicable limitation period and on the basis of incriminating material that is clearly linked to a specific assessment year. Here, the notices were issued about 15 months after completion of the searched person&#039;s assessment, beyond the period recognised in binding precedent, and the COVID-19 relaxation did not cure the delay, so the notices were time barred and invalid. The satisfaction note was also defective because it relied on an undated, unsigned loose sheet, did not clearly identify the relevant year or its impact on total income, and reflected borrowed rather than independent satisfaction. The assessments were quashed.</description>
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