Atul Vijay Madan v. DCIT(2025) 237 TTJ 220 (Pune)(Trib)

S. 147: Reassessment-Search-Incriminating documents-Notice issued on the basis of documents seized from a third party not pertaining to the assessee-Reassessment was quashed. [S. 69, 148, 153C]

Held that the notice under S 148, issued to the assessee based on the document seized during the search in the case of Kokani  Group, is bad in law as none of the seized documents pertains to the assesse. Reassessment was quashed. Tribunal also held that the advance pertains to an earlier year, and same is established by the opening balance in the ledger account impugned addition is directed to be deleted (AY. 2012-13)

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