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    <title>2026 (5) TMI 1140 - ITAT AHMEDABAD</title>
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    <description>Reassessment based solely on search material relating to a third party must proceed under the special search-related mechanism in section 153C, not the general reassessment route under sections 147/148, unless the statutory satisfaction requirement is first met and independent post-search material exists. On the facts described, the reassessment was held without jurisdiction because the material came exclusively from a search on another person and the required satisfaction note was absent, so the reassessment orders were quashed. The separate objection of borrowed satisfaction from investigation material was noted, but it did not affect the result once the jurisdictional defect under section 153C was established.</description>
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      <title>2026 (5) TMI 1140 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=791938</link>
      <description>Reassessment based solely on search material relating to a third party must proceed under the special search-related mechanism in section 153C, not the general reassessment route under sections 147/148, unless the statutory satisfaction requirement is first met and independent post-search material exists. On the facts described, the reassessment was held without jurisdiction because the material came exclusively from a search on another person and the required satisfaction note was absent, so the reassessment orders were quashed. The separate objection of borrowed satisfaction from investigation material was noted, but it did not affect the result once the jurisdictional defect under section 153C was established.</description>
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