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    <title>2025 (3) TMI 1696 - ITAT BANGALORE</title>
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    <description>Reassessment under sections 147/148 was held to be without jurisdiction where the proposed addition was based on material seized in a search under section 132 relating to a person other than the searched person. The proper statutory route in such a case was section 153C, because the reasons recorded and the assessment order showed that the income sought to be taxed flowed directly from seized search material. As the proceedings were initiated under the wrong provision, the reopening could not be sustained, the jurisdictional objection succeeded, and the assessment was set aside.</description>
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    <pubDate>Fri, 28 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 1696 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=469114</link>
      <description>Reassessment under sections 147/148 was held to be without jurisdiction where the proposed addition was based on material seized in a search under section 132 relating to a person other than the searched person. The proper statutory route in such a case was section 153C, because the reasons recorded and the assessment order showed that the income sought to be taxed flowed directly from seized search material. As the proceedings were initiated under the wrong provision, the reopening could not be sustained, the jurisdictional objection succeeded, and the assessment was set aside.</description>
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      <pubDate>Fri, 28 Mar 2025 00:00:00 +0530</pubDate>
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