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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. The prescribed investigating-officer certificate, approved by the Director General of Income Tax and communicated to jurisdictional authorities, is required where no investigation is needed for other assessment years; non-compliance invalidates requisition-based assessments for those years. Separately, cash is not unexplained where its source is supported by bank withdrawals, recorded cash balances and unrejected books of account. The notes state that the assessment was quashed and the cash addition could not be sustained.</description>
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