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    <title>2024 (12) TMI 1785 - ITAT HYDERABAD</title>
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    <description>Section 153C assessments require additions to rest on incriminating seized material identified in the assessee&#039;s jurisdictional satisfaction note and attributable to the relevant assessment year. Material from different annexures could not support additions where it was not included in that note. Seized material concerning an amalgamated company that had ceased to exist could not be used against the assessee without a fresh satisfaction that the material belonged to the assessee. A composite satisfaction covering multiple years also failed to identify year-specific material. The notes state that the Section 153C proceedings and consequential assessments were treated as invalid, sustaining relief to the assessee.</description>
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    <pubDate>Thu, 19 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 1785 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=470426</link>
      <description>Section 153C assessments require additions to rest on incriminating seized material identified in the assessee&#039;s jurisdictional satisfaction note and attributable to the relevant assessment year. Material from different annexures could not support additions where it was not included in that note. Seized material concerning an amalgamated company that had ceased to exist could not be used against the assessee without a fresh satisfaction that the material belonged to the assessee. A composite satisfaction covering multiple years also failed to identify year-specific material. The notes state that the Section 153C proceedings and consequential assessments were treated as invalid, sustaining relief to the assessee.</description>
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      <pubDate>Thu, 19 Dec 2024 00:00:00 +0530</pubDate>
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