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Applicability of Section 153C and Section 148 of the Income Tax Act in cases involving seizure of incriminating material during search or requisition of documents related to an assessee other than the one against whom the search was conducted. The Rajasthan High Court's judgment clarified that if the twin conditions for invoking Section 153C are satisfied, the Assessing Officer must proceed u/s 153C, issuing notices for filing returns for relevant preceding years and assessing or reassessing the total income. Resorting to Section 148 is not permissible in such cases. The findings of the Delhi ITAT in the case of M/s Mah Impex Pvt. Ltd. involving the Surendra Kumar Jain Group were applied, allowing the assessee's appeal.
Applicability of Section 153C and Section 148 of the Income Tax Act in cases involving seizure of incriminating material during search or requisition of documents related to an assessee other than the one against whom the search was conducted. The Rajasthan High Court's judgment clarified that if the twin conditions for invoking Section 153C are satisfied, the Assessing Officer must proceed u/s 153C, issuing notices for filing returns for relevant preceding years and assessing or reassessing the total income. Resorting to Section 148 is not permissible in such cases. The findings of the Delhi ITAT in the case of M/s Mah Impex Pvt. Ltd. involving the Surendra Kumar Jain Group were applied, allowing the assessee's appeal.
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