https://www.taxtmi.com/caselaws?id=768625 ITAT Chandigarh quashed reassessment proceedings initiated u/s 147 where loose papers pertaining to third party were found during search. Tribunal held AO should have proceeded u/s 153C instead of 147/148 as documents were seized from searched person. AO failed to follow mandatory procedure requiring satisfaction from searched person's AO before transmitting matter. Addition of Rs.13 Cr undisclosed income deleted as AO lacked material evidence beyond statement of accountant against whom FIR was lodged. Assessment also quashed for non-issuance of notice u/s 143(2) which is prerequisite before scrutiny. Penalty u/s 271D deleted as underlying addition was removed and amount didn't constitute loan/deposit under Section 269SS. en-us Mon, 07 Apr 2025 00:00:00 +0530 Wed, 09 Apr 2025 13:48:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768625 ITAT Chandigarh quashed reassessment proceedings initiated u/s 147 where loose papers pertaining to third party were found during search. Tribunal held AO should have proceeded u/s 153C instead of 147/148 as documents were seized from searched person. AO failed to follow mandatory procedure requiring satisfaction from searched person's AO before transmitting matter. Addition of Rs.13 Cr undisclosed income deleted as AO lacked material evidence beyond statement of accountant against whom FIR was lodged. Assessment also quashed for non-issuance of notice u/s 143(2) which is prerequisite before scrutiny. Penalty u/s 271D deleted as underlying addition was removed and amount didn't constitute loan/deposit under Section 269SS. Case-Laws Income Tax Mon, 07 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768625