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HC determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating evidence emerges from search, Revenue must proceed under s.153A/153C framework. The case originated from search of Shilpi Jewellers Pvt Ltd revealing accommodation entries through shell company Green Valley Gems Pvt Ltd. Court held that since foundation was search action yielding new materials, Revenue cannot bypass s.153A/153C by invoking s.147/148. Legislature intended these provisions to operate in distinct spheres, with s.153A containing non-obstante clause creating exception to regular reassessment under s.147. Notice under s.147 and subsequent actions declared without jurisdiction and void.
HC determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating evidence emerges from search, Revenue must proceed under s.153A/153C framework. The case originated from search of Shilpi Jewellers Pvt Ltd revealing accommodation entries through shell company Green Valley Gems Pvt Ltd. Court held that since foundation was search action yielding new materials, Revenue cannot bypass s.153A/153C by invoking s.147/148. Legislature intended these provisions to operate in distinct spheres, with s.153A containing non-obstante clause creating exception to regular reassessment under s.147. Notice under s.147 and subsequent actions declared without jurisdiction and void.
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