https://www.taxtmi.com/caselaws?id=761903 ITAT Delhi held that reopening assessment under Section 147 based on materials found during search of third party premises is invalid. When documents relating to assessee are discovered during search of third party (Jain brothers), assessment can only be made under Section 153C, not through reopening proceedings under Sections 147/148. The tribunal ruled that initiation of proceedings under Section 148 based on third party search materials is legally unsustainable. Assessment was declared void ab-initio and quashed. Assessee's appeal allowed. en-us Fri, 18 Oct 2024 00:00:00 +0530 Wed, 20 Nov 2024 08:47:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761903 ITAT Delhi held that reopening assessment under Section 147 based on materials found during search of third party premises is invalid. When documents relating to assessee are discovered during search of third party (Jain brothers), assessment can only be made under Section 153C, not through reopening proceedings under Sections 147/148. The tribunal ruled that initiation of proceedings under Section 148 based on third party search materials is legally unsustainable. Assessment was declared void ab-initio and quashed. Assessee's appeal allowed. Case-Laws Income Tax Fri, 18 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761903