https://www.taxtmi.com/caselaws?id=751656 ITAT Visakhapatnam held that assessment proceedings under section 147 were void-ab-initio where the AO relied solely on seized documents from search operations. The tribunal ruled that when AO acts based on seized material from searched premises without fresh information from normal course, assessment must be framed under section 153C, not section 147. Since section 153C overrides sections 139, 147, 148, and 151, and the AO failed to record any independent information beyond seized documents, the assessment order was quashed as procedurally invalid. en-us Thu, 18 Apr 2024 00:00:00 +0530 Sat, 20 Apr 2024 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751656 ITAT Visakhapatnam held that assessment proceedings under section 147 were void-ab-initio where the AO relied solely on seized documents from search operations. The tribunal ruled that when AO acts based on seized material from searched premises without fresh information from normal course, assessment must be framed under section 153C, not section 147. Since section 153C overrides sections 139, 147, 148, and 151, and the AO failed to record any independent information beyond seized documents, the assessment order was quashed as procedurally invalid. Case-Laws Income Tax Thu, 18 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751656