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ITAT held that where documents seized during a search pertain to a third party, the mandatory procedure is to proceed under Section 153C, not Section 147. The AO's reassessment notice was deemed invalid due to significant procedural irregularities, specifically: (1) deviation from original reassessment grounds, (2) making additions on unrelated grounds, and (3) improperly assuming jurisdiction. The tribunal emphasized that utilizing seized third-party documents requires strict adherence to statutory provisions, rendering the assessment order unsustainable and lacking legal sanctity.
ITAT held that where documents seized during a search pertain to a third party, the mandatory procedure is to proceed under Section 153C, not Section 147. The AO's reassessment notice was deemed invalid due to significant procedural irregularities, specifically: (1) deviation from original reassessment grounds, (2) making additions on unrelated grounds, and (3) improperly assuming jurisdiction. The tribunal emphasized that utilizing seized third-party documents requires strict adherence to statutory provisions, rendering the assessment order unsustainable and lacking legal sanctity.
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