https://www.taxtmi.com/highlights?id=87318 ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings. en-us Thu, 10 Apr 2025 08:32:54 +0530 Thu, 10 Apr 2025 08:32:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=87318 ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings. Highlights Income Tax Thu, 10 Apr 2025 08:32:54 +0530 https://www.taxtmi.com/highlights?id=87318