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    <title>2026 (6) TMI 927 - ITAT MUMBAI</title>
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    <description>The delay in filing the appeal was condoned because it was not deliberate and arose from bona fide reasons, and the additional ground was admitted as a pure question of law going to jurisdiction. On merits, where the reassessment was founded on search material relating to a searched party and a related person, the special scheme under section 153C was held to be the mandatory route. Resort to the general reassessment provisions under sections 147 and 148 was impermissible, so those proceedings and all consequential actions were quashed as without jurisdiction.</description>
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      <description>The delay in filing the appeal was condoned because it was not deliberate and arose from bona fide reasons, and the additional ground was admitted as a pure question of law going to jurisdiction. On merits, where the reassessment was founded on search material relating to a searched party and a related person, the special scheme under section 153C was held to be the mandatory route. Resort to the general reassessment provisions under sections 147 and 148 was impermissible, so those proceedings and all consequential actions were quashed as without jurisdiction.</description>
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