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Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
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