https://www.taxtmi.com/caselaws?id=791999 Limitation under Section 153 was applied to hold that the assessment for assessment year 2022-23 was time-barred, because the exclusion in clause (xii) of Explanation 1 covered only the period actually lost in handing over seized material and did not extend the statutory period beyond that basis. The additions under Section 56(2)(x) were deleted because the case rested on third-party seized material, which did not attract the presumptions under Sections 132(4A) and 292C against the assessee without independent corroboration; the pen drive extract also lacked evidentiary value without a Section 65B certificate. In the absence of proof of the assessee's role or receipt of consideration, the statutory ingredients were not established. en-us Fri, 15 May 2026 00:00:00 +0530 Thu, 21 May 2026 08:30:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791999 Limitation under Section 153 was applied to hold that the assessment for assessment year 2022-23 was time-barred, because the exclusion in clause (xii) of Explanation 1 covered only the period actually lost in handing over seized material and did not extend the statutory period beyond that basis. The additions under Section 56(2)(x) were deleted because the case rested on third-party seized material, which did not attract the presumptions under Sections 132(4A) and 292C against the assessee without independent corroboration; the pen drive extract also lacked evidentiary value without a Section 65B certificate. In the absence of proof of the assessee's role or receipt of consideration, the statutory ingredients were not established. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791999