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    <title>2026 (5) TMI 1053 - ITAT PUNE</title>
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    <description>In search-related assessments, the Tribunal applied the statutory distinction between section 153A for the searched person and section 153C where material belongs to or relates to another person, and upheld jurisdiction under section 153C. It sustained estimated commission income from alleged hawala or accommodation entries only at a reduced rate of 0.3% because no direct evidence of higher commission was found. Cash receipt, where the explanation remained unsupported by documentary proof, was confirmed as an addition. By contrast, the addition based on an alleged payment from Sinhagad Technical Education Society was deleted for lack of corroboration, unexplained jewellery was deleted applying CBDT Instruction No. 1916, and additions founded on third-party seized papers were deleted because the documents lacked independent corroboration.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791851</link>
      <description>In search-related assessments, the Tribunal applied the statutory distinction between section 153A for the searched person and section 153C where material belongs to or relates to another person, and upheld jurisdiction under section 153C. It sustained estimated commission income from alleged hawala or accommodation entries only at a reduced rate of 0.3% because no direct evidence of higher commission was found. Cash receipt, where the explanation remained unsupported by documentary proof, was confirmed as an addition. By contrast, the addition based on an alleged payment from Sinhagad Technical Education Society was deleted for lack of corroboration, unexplained jewellery was deleted applying CBDT Instruction No. 1916, and additions founded on third-party seized papers were deleted because the documents lacked independent corroboration.</description>
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