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Third-party search material forming the foundation for...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedings' foundation.
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Third-party search material forming the foundation for assessment of a person other than the searched person requires use of the special assessment procedure under section 153C. Its overriding clause displaces general reassessment under sections 147 and 148, even where the Revenue subsequently analyses or corroborates the seized material and treats it as information indicating escaped income. Because the alleged transactions, taxpayer identification and inference of unaccounted income originated in seized material, the section 148A(d) order and consequential section 148 notice lacked jurisdiction and were quashed.
Third-party search material forming the foundation for assessment of a person other than the searched person requires use of the special assessment procedure under section 153C. Its overriding clause displaces general reassessment under sections 147 and 148, even where the Revenue subsequently analyses or corroborates the seized material and treats it as information indicating escaped income. Because the alleged transactions, taxpayer identification and inference of unaccounted income originated in seized material, the section 148A(d) order and consequential section 148 notice lacked jurisdiction and were quashed.
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