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Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying Section 153C when incriminating material pertaining to a person other than the searched party is found. Citing relevant judicial precedents, including decisions from the Supreme Court and High Courts, the Tribunal concluded that the AO should have initiated proceedings under Section 153C instead of Section 147. As the AO failed to present any additional information beyond the seized documents, the Tribunal deemed the assessment order void-ab-initio and upheld the appellant's contention regarding the invalidity of the notice issued under Section 148.
Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying Section 153C when incriminating material pertaining to a person other than the searched party is found. Citing relevant judicial precedents, including decisions from the Supreme Court and High Courts, the Tribunal concluded that the AO should have initiated proceedings under Section 153C instead of Section 147. As the AO failed to present any additional information beyond the seized documents, the Tribunal deemed the assessment order void-ab-initio and upheld the appellant's contention regarding the invalidity of the notice issued under Section 148.
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