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    <title>2026 (5) TMI 1414 - ITAT DELHI</title>
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    <description>Where additions rest on documents seized from a third person, the Assessing Officer must use the reassessment framework and comply with the prescribed satisfaction and approval requirements; an assessment under section 143(3) cannot bypass that statutory route. The article notes that, for an assessment year prior to the search year, the Tribunal followed coordinate bench rulings treating third-party seized material as triggering deemed escapement only through reassessment provisions. Because the assessment in question was completed under section 143(3) on the basis of third-party documents and statements, the procedure adopted was contrary to law and the assessment was quashed.</description>
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    <pubDate>Wed, 20 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1414 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792212</link>
      <description>Where additions rest on documents seized from a third person, the Assessing Officer must use the reassessment framework and comply with the prescribed satisfaction and approval requirements; an assessment under section 143(3) cannot bypass that statutory route. The article notes that, for an assessment year prior to the search year, the Tribunal followed coordinate bench rulings treating third-party seized material as triggering deemed escapement only through reassessment provisions. Because the assessment in question was completed under section 143(3) on the basis of third-party documents and statements, the procedure adopted was contrary to law and the assessment was quashed.</description>
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      <pubDate>Wed, 20 May 2026 00:00:00 +0530</pubDate>
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