https://www.taxtmi.com/caselaws?id=764179 ITAT Delhi upheld the validity of reopening assessment under sections 147/148 despite the existence of section 153C, ruling that non-obstante clause in 153C does not bar reopening proceedings. The assessee failed to file search records and bank statements, and could not challenge AO's jurisdiction under section 124(3). The tribunal found merit in revenue's arguments based on tangible materials and recorded reasons. Penalty under section 271(1)(C) for concealment was upheld as the assessee provided no reasonable explanation, with the tribunal citing relevant precedents to confirm the lower authorities' decision. en-us Tue, 31 Dec 2024 00:00:00 +0530 Fri, 03 Jan 2025 10:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764179 ITAT Delhi upheld the validity of reopening assessment under sections 147/148 despite the existence of section 153C, ruling that non-obstante clause in 153C does not bar reopening proceedings. The assessee failed to file search records and bank statements, and could not challenge AO's jurisdiction under section 124(3). The tribunal found merit in revenue's arguments based on tangible materials and recorded reasons. Penalty under section 271(1)(C) for concealment was upheld as the assessee provided no reasonable explanation, with the tribunal citing relevant precedents to confirm the lower authorities' decision. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764179