https://www.taxtmi.com/caselaws?id=769640 The ITAT Bangalore ruled that the AO erred in issuing notice under section 148 instead of section 153C when incriminating materials were seized during searches conducted on other parties. The search was conducted in 2010 and 2013 on different entities, with the assessee's case centralized in 2012. Since seized materials pertained to the assessee's transactions and the time limit for section 153C proceedings had not expired, the AO was required to follow section 153C procedure rather than section 147/148. The tribunal dismissed the revenue's appeals, upholding that proceedings under section 147 were bad in law when based on seized materials. en-us Fri, 31 Jan 2025 00:00:00 +0530 Tue, 29 Apr 2025 08:33:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769640 The ITAT Bangalore ruled that the AO erred in issuing notice under section 148 instead of section 153C when incriminating materials were seized during searches conducted on other parties. The search was conducted in 2010 and 2013 on different entities, with the assessee's case centralized in 2012. Since seized materials pertained to the assessee's transactions and the time limit for section 153C proceedings had not expired, the AO was required to follow section 153C procedure rather than section 147/148. The tribunal dismissed the revenue's appeals, upholding that proceedings under section 147 were bad in law when based on seized materials. Case-Laws Income Tax Fri, 31 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769640