https://www.taxtmi.com/caselaws?id=459455 ITAT Delhi quashed assessment proceedings under Section 147 where incriminating material regarding payment to Santosh Medical College was found during search of another person. The tribunal held that since material was seized from third party search, assessment should have been under Section 153C, not Section 147. The AO erred in invoking Section 147 as Section 153C specifically excludes Section 147 operations. Reasons recorded under Section 147 and subsequent proceedings including the appealed order were quashed. en-us Wed, 19 Jul 2023 00:00:00 +0530 Fri, 13 Dec 2024 19:06:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459455 ITAT Delhi quashed assessment proceedings under Section 147 where incriminating material regarding payment to Santosh Medical College was found during search of another person. The tribunal held that since material was seized from third party search, assessment should have been under Section 153C, not Section 147. The AO erred in invoking Section 147 as Section 153C specifically excludes Section 147 operations. Reasons recorded under Section 147 and subsequent proceedings including the appealed order were quashed. Case-Laws Income Tax Wed, 19 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459455