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    <title>2025 (9) TMI 1817 - ITAT MUMBAI</title>
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    <description>Section 153C was applied from the date the seized material reached the Assessing Officer of the other person, so the six-year span ran from AY 2013-14 to AY 2018-19; AYs 2011-12 and 2012-13 were outside scope, and AY 2017-18 could not be completed under section 143(3). Additions for alleged capitation fee were deleted because the material came from employees and third parties, with no independent corroboration against the assessee and retracted statements lacking reliability. Exemption under section 11 was therefore not denied. Major relief was also upheld on corpus donations and development fees, while one donation was remanded for verification, foreign currency was sent back for factual examination, and rejection of books and related depreciation issues were only partly sustained.</description>
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    <pubDate>Thu, 04 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 1817 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=469515</link>
      <description>Section 153C was applied from the date the seized material reached the Assessing Officer of the other person, so the six-year span ran from AY 2013-14 to AY 2018-19; AYs 2011-12 and 2012-13 were outside scope, and AY 2017-18 could not be completed under section 143(3). Additions for alleged capitation fee were deleted because the material came from employees and third parties, with no independent corroboration against the assessee and retracted statements lacking reliability. Exemption under section 11 was therefore not denied. Major relief was also upheld on corpus donations and development fees, while one donation was remanded for verification, foreign currency was sent back for factual examination, and rejection of books and related depreciation issues were only partly sustained.</description>
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