https://www.taxtmi.com/caselaws?id=769344 The ITAT Mumbai held that assessment under Section 147 was invalid where documents were seized from third-party premises during search operations. The tribunal ruled that when documents belong to persons other than the searched party, proceedings must be initiated under Section 153C, not Section 147. The AO lacked jurisdiction as no new information was discovered during normal assessment proceedings, and the final additions were made on grounds different from those recorded in the reassessment notice, undermining the assumed jurisdiction. en-us Mon, 21 Apr 2025 00:00:00 +0530 Thu, 24 Apr 2025 09:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769344 The ITAT Mumbai held that assessment under Section 147 was invalid where documents were seized from third-party premises during search operations. The tribunal ruled that when documents belong to persons other than the searched party, proceedings must be initiated under Section 153C, not Section 147. The AO lacked jurisdiction as no new information was discovered during normal assessment proceedings, and the final additions were made on grounds different from those recorded in the reassessment notice, undermining the assumed jurisdiction. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769344