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    <title>2026 (6) TMI 144 - ITAT PUNE</title>
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    <description>Where search material from third parties does not satisfy the statutory preconditions for section 153C action against a person other than the searched person, reassessment may still be sustained under section 147 if the Assessing Officer has independently received tangible information and recorded reasons to believe. The Tribunal noted that the seized diaries and documents were not found from the assessee and that the Investigation Wing forwarded the material before reassessment was completed through the prescribed procedure. It therefore rejected the contention that section 153C was the only permissible route and upheld the reassessment jurisdiction.</description>
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    <pubDate>Wed, 20 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 144 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=792763</link>
      <description>Where search material from third parties does not satisfy the statutory preconditions for section 153C action against a person other than the searched person, reassessment may still be sustained under section 147 if the Assessing Officer has independently received tangible information and recorded reasons to believe. The Tribunal noted that the seized diaries and documents were not found from the assessee and that the Investigation Wing forwarded the material before reassessment was completed through the prescribed procedure. It therefore rejected the contention that section 153C was the only permissible route and upheld the reassessment jurisdiction.</description>
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      <pubDate>Wed, 20 May 2026 00:00:00 +0530</pubDate>
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