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    <title>2026 (5) TMI 1254 - ITAT AHMEDABAD</title>
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    <description>Section 148A(d) must be passed within its mandatory statutory deadline, and that limit is not extended by any surviving time for issuing notice under section 148; on the stated facts, the order was time-barred and the consequential notice was void. Where reassessment is based solely on third-party search material, the special procedure under section 153C applies, and sections 147/148 cannot be used to bypass it; in the stated facts, the reassessment lacked jurisdiction. The additions under sections 68 and 69A were also unsustainable because the record included sales invoices, ledger accounts, lorry receipts, confirmations and audited books, while the revenue did not reject the books or make a proper inquiry into the alleged unexplained credits.</description>
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    <pubDate>Fri, 24 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=792052</link>
      <description>Section 148A(d) must be passed within its mandatory statutory deadline, and that limit is not extended by any surviving time for issuing notice under section 148; on the stated facts, the order was time-barred and the consequential notice was void. Where reassessment is based solely on third-party search material, the special procedure under section 153C applies, and sections 147/148 cannot be used to bypass it; in the stated facts, the reassessment lacked jurisdiction. The additions under sections 68 and 69A were also unsustainable because the record included sales invoices, ledger accounts, lorry receipts, confirmations and audited books, while the revenue did not reject the books or make a proper inquiry into the alleged unexplained credits.</description>
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      <pubDate>Fri, 24 Apr 2026 00:00:00 +0530</pubDate>
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