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    <title>2026 (6) TMI 975 - ITAT JAIPUR</title>
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    <description>Jurisdiction under section 153C was upheld where the Assessing Officer recorded satisfaction on seized material, even though the information originated from the Investigation Wing and the same officer assessed both persons. The proceedings under sections 153C and 153B were nevertheless held time-barred, as the satisfaction note and assessment were recorded beyond the permissible limitation period, rendering the assessments void ab initio. Additions under section 69A and the consequential section 115BBE levy were deleted because the alleged nexus rested on uncorroborated electronic extracts and third-party statements, with no meaningful cross-examination and insufficient reliable evidence linking the material to the assessee.</description>
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      <title>2026 (6) TMI 975 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=793594</link>
      <description>Jurisdiction under section 153C was upheld where the Assessing Officer recorded satisfaction on seized material, even though the information originated from the Investigation Wing and the same officer assessed both persons. The proceedings under sections 153C and 153B were nevertheless held time-barred, as the satisfaction note and assessment were recorded beyond the permissible limitation period, rendering the assessments void ab initio. Additions under section 69A and the consequential section 115BBE levy were deleted because the alleged nexus rested on uncorroborated electronic extracts and third-party statements, with no meaningful cross-examination and insufficient reliable evidence linking the material to the assessee.</description>
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