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    <title>2026 (7) TMI 288 - ITAT KOLKATA</title>
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    <description>Where reassessment was triggered by material seized in a third-party search, the special search-assessment machinery under section 153C, read with the proviso to section 149(1), governed the matter; resort to sections 147 and 148 was therefore impermissible, and the reopening was held invalid. Additions based on third-party documents and statements also failed because the material was not confronted to the assessee and the deponents were not offered for cross-examination, rendering the findings contrary to natural justice. The reassessment and consequential additions were deleted, with relief granted to the assessee.</description>
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      <title>2026 (7) TMI 288 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=794402</link>
      <description>Where reassessment was triggered by material seized in a third-party search, the special search-assessment machinery under section 153C, read with the proviso to section 149(1), governed the matter; resort to sections 147 and 148 was therefore impermissible, and the reopening was held invalid. Additions based on third-party documents and statements also failed because the material was not confronted to the assessee and the deponents were not offered for cross-examination, rendering the findings contrary to natural justice. The reassessment and consequential additions were deleted, with relief granted to the assessee.</description>
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