https://www.taxtmi.com/caselaws?id=285510 The ITAT Delhi held that reopening of assessment u/s 147 and addition u/s 69C for alleged unexplained expenditure was void ab initio. Since a search operation was conducted at premises of a group of institutions, any documents found made the assessee an "other person" under the Act, requiring proceedings to be initiated u/s 153C rather than u/s 147/148. Following the coordinate bench decision in an identical case involving the same institution, the tribunal ruled that the notice u/s 148 and assessment u/s 147 were invalid from inception. en-us Fri, 30 Nov 2018 00:00:00 +0530 Mon, 09 Jun 2025 14:52:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285510 The ITAT Delhi held that reopening of assessment u/s 147 and addition u/s 69C for alleged unexplained expenditure was void ab initio. Since a search operation was conducted at premises of a group of institutions, any documents found made the assessee an "other person" under the Act, requiring proceedings to be initiated u/s 153C rather than u/s 147/148. Following the coordinate bench decision in an identical case involving the same institution, the tribunal ruled that the notice u/s 148 and assessment u/s 147 were invalid from inception. Case-Laws Income Tax Fri, 30 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285510