https://www.taxtmi.com/caselaws?id=760328 The ITAT Delhi held that assessment proceedings under sections 147/148 cannot be initiated for assessment years covered under section 153A when a search under section 132 or requisition under section 132A has occurred. The tribunal ruled that section 153A mandatorily requires assessment proceedings to be completed under its provisions for the specified years (now ten years), creating an overriding effect over regular assessment provisions. The AO's addition based on documents found during search was invalid as proper section 153A procedures were not followed. The case was decided in favor of the assessee. en-us Tue, 15 Oct 2024 00:00:00 +0530 Fri, 18 Oct 2024 12:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760328 The ITAT Delhi held that assessment proceedings under sections 147/148 cannot be initiated for assessment years covered under section 153A when a search under section 132 or requisition under section 132A has occurred. The tribunal ruled that section 153A mandatorily requires assessment proceedings to be completed under its provisions for the specified years (now ten years), creating an overriding effect over regular assessment provisions. The AO's addition based on documents found during search was invalid as proper section 153A procedures were not followed. The case was decided in favor of the assessee. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760328