https://www.taxtmi.com/caselaws?id=459470 ITAT Bangalore set aside assessment proceedings initiated under Section 147/148 against assessee based on documents found during search of third party. Court held that AO lacked jurisdiction as proceedings should have been initiated under Section 153C, which specifically addresses persons other than the searched party. The amendment changing "belongs to" to "pertains to" in Section 153C clarified Parliament's intent following Pepsico India Holdings case. Wrong initiation under Section 148 instead of Section 153C constituted jurisdictional error, rendering entire proceedings invalid and liable to be set aside. en-us Thu, 26 Oct 2023 00:00:00 +0530 Sat, 14 Dec 2024 14:21:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459470 ITAT Bangalore set aside assessment proceedings initiated under Section 147/148 against assessee based on documents found during search of third party. Court held that AO lacked jurisdiction as proceedings should have been initiated under Section 153C, which specifically addresses persons other than the searched party. The amendment changing "belongs to" to "pertains to" in Section 153C clarified Parliament's intent following Pepsico India Holdings case. Wrong initiation under Section 148 instead of Section 153C constituted jurisdictional error, rendering entire proceedings invalid and liable to be set aside. Case-Laws Income Tax Thu, 26 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459470