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    <title>2026 (8) TMI 48 - ITAT DELHI</title>
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    <description>For assessments under section 153C, where the Assessing Officer of the searched person and the other person is the same, transfer of the other person&#039;s case and seized material to that officer is treated as the relevant handing-over date. Where records were transferred under section 127 before the satisfaction note was recorded, limitation runs from the transfer order, not from the later satisfaction note. On the stated facts, the assessments were treated as time-barred and quashed.</description>
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