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    <title>2026 (5) TMI 600 - ITAT DELHI</title>
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    <description>Under the amended section 153C of the Income-tax Act, jurisdiction for search-based assessment of a non-searched person depends on the statutory cut-off introduced by the Finance Act, 2021. Where the satisfaction note was recorded on 28.09.2021 and the record did not show that seized material had been received by the Assessing Officer earlier, the notice and assessment under section 153C were treated as without jurisdiction. Once this jurisdictional defect was found, the addition on merits was not separately sustained and the assessments were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791398</link>
      <description>Under the amended section 153C of the Income-tax Act, jurisdiction for search-based assessment of a non-searched person depends on the statutory cut-off introduced by the Finance Act, 2021. Where the satisfaction note was recorded on 28.09.2021 and the record did not show that seized material had been received by the Assessing Officer earlier, the notice and assessment under section 153C were treated as without jurisdiction. Once this jurisdictional defect was found, the addition on merits was not separately sustained and the assessments were quashed.</description>
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