https://www.taxtmi.com/caselaws?id=762084 The Delhi HC ruled in favor of the assessee regarding the choice between assessment under Section 147 versus Section 153C. The assessee's name appeared in beneficiary lists for accommodation entries through share capital premium/loan. The court held that conditions for reopening assessment under Section 153C were not satisfied as no satisfaction note was recorded by the AO of the searched person. The AO correctly proceeded under Section 147/148 based on Investigation Wing information received on 12.03.2013, since reassessment under Section 153C was impermissible at that time. The jurisdictional condition for assuming jurisdiction under Section 153C was not met. The appeal was allowed and restored to ITAT for consideration on other grounds. en-us Wed, 20 Nov 2024 00:00:00 +0530 Fri, 22 Nov 2024 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762084 The Delhi HC ruled in favor of the assessee regarding the choice between assessment under Section 147 versus Section 153C. The assessee's name appeared in beneficiary lists for accommodation entries through share capital premium/loan. The court held that conditions for reopening assessment under Section 153C were not satisfied as no satisfaction note was recorded by the AO of the searched person. The AO correctly proceeded under Section 147/148 based on Investigation Wing information received on 12.03.2013, since reassessment under Section 153C was impermissible at that time. The jurisdictional condition for assuming jurisdiction under Section 153C was not met. The appeal was allowed and restored to ITAT for consideration on other grounds. Case-Laws Income Tax Wed, 20 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762084