https://www.taxtmi.com/caselaws?id=459178 ITAT Delhi upheld CIT(A)'s decision quashing reassessment proceedings under section 147. The tribunal held that when additions are based on incriminating material seized from third party (Alankit Group) during search operations, proper procedure requires initiation of proceedings under section 153C, not section 147. The decision followed Karnataka HC precedent in Sri Dinakara Suvarna case, applying Supreme Court ratio from Manish Maheshwari case. Revenue's appeal was dismissed as AO showed patent non-application of mind by not initiating section 153C proceedings despite having seized materials pertaining to assessee from third party search. en-us Mon, 08 Jul 2024 00:00:00 +0530 Tue, 03 Dec 2024 19:05:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459178 ITAT Delhi upheld CIT(A)'s decision quashing reassessment proceedings under section 147. The tribunal held that when additions are based on incriminating material seized from third party (Alankit Group) during search operations, proper procedure requires initiation of proceedings under section 153C, not section 147. The decision followed Karnataka HC precedent in Sri Dinakara Suvarna case, applying Supreme Court ratio from Manish Maheshwari case. Revenue's appeal was dismissed as AO showed patent non-application of mind by not initiating section 153C proceedings despite having seized materials pertaining to assessee from third party search. Case-Laws Income Tax Mon, 08 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459178