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ITAT dismissed Revenue's appeal challenging CIT(A)'s order quashing assessment u/s 153A. Tribunal held that assessment u/s 153A cannot be sustained against person in whose name search warrant was not issued under section 132. Since search action was not initiated against the assessee, AO lacked jurisdiction to assume proceedings u/s 153A. Following precedent in Sanjay Jain case with identical facts and circumstances, ITAT affirmed CIT(A)'s decision quashing the reopening proceedings. Revenue's contention regarding assumption of jurisdiction was rejected, and assessee's appeal was allowed on grounds of procedural impropriety in initiating assessment without proper search warrant authorization.
ITAT dismissed Revenue's appeal challenging CIT(A)'s order quashing assessment u/s 153A. Tribunal held that assessment u/s 153A cannot be sustained against person in whose name search warrant was not issued under section 132. Since search action was not initiated against the assessee, AO lacked jurisdiction to assume proceedings u/s 153A. Following precedent in Sanjay Jain case with identical facts and circumstances, ITAT affirmed CIT(A)'s decision quashing the reopening proceedings. Revenue's contention regarding assumption of jurisdiction was rejected, and assessee's appeal was allowed on grounds of procedural impropriety in initiating assessment without proper search warrant authorization.
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