Jurisdictional Defects Vitiate Entire Assessment: ITAT Strikes Down Additions Based on Search Material

Miraj Products Pvt. Ltd. Vs ACIT (ITAT Jodhpur) Conclusion: Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.  Loose, handwritten “dumped documents” recovered from a third party hold no evidentiary weight against an assessee. Clandestine manufacturing and sales charges could not stand on raw suspicion or reverse-engineered l...