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    <title>2026 (7) TMI 1235 - ITAT MUMBAI</title>
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    <description>Section 153A proceedings based on cash requisitioned during an election period require compliance with Rule 112F and Circular No. 10/2012. Where no investigating-officer certificate, approved by the Director General of Income Tax, was issued or communicated to jurisdictional authorities, notices covering preceding assessment years contravened the prescribed election-period safeguards and the assessment was invalid. Separately, cash supported by recorded bank withdrawals and the cash book could not be treated as unexplained where the books were not rejected and the source was established. The assessment machinery could not be invoked without the required Rule 112F certification.</description>
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      <description>Section 153A proceedings based on cash requisitioned during an election period require compliance with Rule 112F and Circular No. 10/2012. Where no investigating-officer certificate, approved by the Director General of Income Tax, was issued or communicated to jurisdictional authorities, notices covering preceding assessment years contravened the prescribed election-period safeguards and the assessment was invalid. Separately, cash supported by recorded bank withdrawals and the cash book could not be treated as unexplained where the books were not rejected and the source was established. The assessment machinery could not be invoked without the required Rule 112F certification.</description>
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