https://www.taxtmi.com/caselaws?id=768295 ITAT Kolkata held that reassessment proceedings u/s 147 were invalid when initiated based on material seized during search u/s 132(1) of another person. The tribunal ruled that Section 153C, containing non-obstante clause, specifically governs such situations and overrides general reassessment provisions. Since information regarding assessee's accommodation entries emerged during search of related parties, department should have invoked Section 153C instead of Sections 147/148. Following Sejal Jewellary precedent, ITAT quashed the reassessment proceedings and allowed assessee's appeal on legal grounds. en-us Tue, 01 Apr 2025 00:00:00 +0530 Fri, 04 Apr 2025 07:15:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768295 ITAT Kolkata held that reassessment proceedings u/s 147 were invalid when initiated based on material seized during search u/s 132(1) of another person. The tribunal ruled that Section 153C, containing non-obstante clause, specifically governs such situations and overrides general reassessment provisions. Since information regarding assessee's accommodation entries emerged during search of related parties, department should have invoked Section 153C instead of Sections 147/148. Following Sejal Jewellary precedent, ITAT quashed the reassessment proceedings and allowed assessee's appeal on legal grounds. Case-Laws Income Tax Tue, 01 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768295