https://www.taxtmi.com/caselaws?id=754866 The ITAT Delhi quashed reassessment proceedings initiated under Section 148 against the assessee. The assessee argued that assessment should have been made under Section 153C based on documents found during third-party search, making Section 148 proceedings illegal. The tribunal found that the AO initially considered Section 153C proceedings but resorted to Section 148 only after time limits elapsed. Since similar Section 153C proceedings against the assessee's brother were dropped, and following the Supreme Court precedent in PCIT vs. Abhisar Buildwell Pvt. Ltd., the reassessment was deemed void ab initio, illegal, and arbitrary. The appeal was allowed. en-us Thu, 27 Jun 2024 00:00:00 +0530 Mon, 01 Jul 2024 10:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754866 The ITAT Delhi quashed reassessment proceedings initiated under Section 148 against the assessee. The assessee argued that assessment should have been made under Section 153C based on documents found during third-party search, making Section 148 proceedings illegal. The tribunal found that the AO initially considered Section 153C proceedings but resorted to Section 148 only after time limits elapsed. Since similar Section 153C proceedings against the assessee's brother were dropped, and following the Supreme Court precedent in PCIT vs. Abhisar Buildwell Pvt. Ltd., the reassessment was deemed void ab initio, illegal, and arbitrary. The appeal was allowed. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754866