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    <title>2026 (6) TMI 461 - ITAT DELHI</title>
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    <description>Unexplained expenditure could not be added merely on the basis of an uncorroborated loose paper found from a third party, because the presumptions under sections 292C and 132(4A) operate only against the person from whose possession the material is seized and not against the assessee without independent corroboration; the addition was deleted. After a search under section 132 initiated on or after 01.04.2021, the prior-year assessment had to proceed through the reassessment framework under sections 147 to 148, with the approval contemplated by section 148B where applicable, and could not be completed under section 143(3); the assessment was quashed.</description>
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    <pubDate>Wed, 06 May 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=793080</link>
      <description>Unexplained expenditure could not be added merely on the basis of an uncorroborated loose paper found from a third party, because the presumptions under sections 292C and 132(4A) operate only against the person from whose possession the material is seized and not against the assessee without independent corroboration; the addition was deleted. After a search under section 132 initiated on or after 01.04.2021, the prior-year assessment had to proceed through the reassessment framework under sections 147 to 148, with the approval contemplated by section 148B where applicable, and could not be completed under section 143(3); the assessment was quashed.</description>
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