https://www.taxtmi.com/caselaws?id=784494 Reassessment under s.147 was challenged as void for want of action under s.153C on the premise that material emanated from a third-party search. The Tribunal held s.153C preconditions were not met because no satisfaction note was recorded or transmitted by the searched person's AO to the assessee's AO; hence recourse to s.153C was unavailable and s.147 could validly be invoked on fresh tangible material indicating bogus s.10(38) exempt LTCG in a tainted scrip. The jurisdictional ground was dismissed. On the s.68 addition treating share-sale proceeds as unexplained, the Tribunal found deficiencies in the assessee's evidence and also non-confrontation of certain third-party data; the matter was set aside to the AO for fresh adjudication with directions to permit further evidence and to furnish relied-upon market/SEBI material. en-us Fri, 02 Jan 2026 00:00:00 +0530 Tue, 06 Jan 2026 08:48:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784494 Reassessment under s.147 was challenged as void for want of action under s.153C on the premise that material emanated from a third-party search. The Tribunal held s.153C preconditions were not met because no satisfaction note was recorded or transmitted by the searched person's AO to the assessee's AO; hence recourse to s.153C was unavailable and s.147 could validly be invoked on fresh tangible material indicating bogus s.10(38) exempt LTCG in a tainted scrip. The jurisdictional ground was dismissed. On the s.68 addition treating share-sale proceeds as unexplained, the Tribunal found deficiencies in the assessee's evidence and also non-confrontation of certain third-party data; the matter was set aside to the AO for fresh adjudication with directions to permit further evidence and to furnish relied-upon market/SEBI material. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784494