https://www.taxtmi.com/caselaws?id=457002 ITAT Amritsar quashed reassessment proceedings under section 147 where incriminating documents were found at third party premises during search operations. The tribunal held that AO should have framed assessment under section 153C instead of reopening under section 147. Following Sanjay Singhal (HUF) precedent, the tribunal ruled that Chapter XIV-B provisions prevail over regular assessment procedures when there is conflict between two procedural streams. Once search-based assessment is framed under section 158BA for undisclosed income, subsequent reopening notices under section 148 are impermissible as section 158BC(a) specifically excludes requirement of section 148 notices for Chapter XIV-B proceedings. en-us Tue, 14 Jun 2022 00:00:00 +0530 Fri, 30 Aug 2024 19:01:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457002 ITAT Amritsar quashed reassessment proceedings under section 147 where incriminating documents were found at third party premises during search operations. The tribunal held that AO should have framed assessment under section 153C instead of reopening under section 147. Following Sanjay Singhal (HUF) precedent, the tribunal ruled that Chapter XIV-B provisions prevail over regular assessment procedures when there is conflict between two procedural streams. Once search-based assessment is framed under section 158BA for undisclosed income, subsequent reopening notices under section 148 are impermissible as section 158BC(a) specifically excludes requirement of section 148 notices for Chapter XIV-B proceedings. Case-Laws Income Tax Tue, 14 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457002