https://www.taxtmi.com/caselaws?id=466723 Where reopening under the income-tax provisions relied exclusively on information and documents seized during a search of a third party, the statutory scheme requires invocation of the special procedure for third party seizures so that the assessing officer of the searched person records satisfaction, forwards material to the AO of the third person, and that AO records satisfaction before initiating reassessment; absent compliance, initiating proceedings under the general reopening provision circumvents these preconditions and is invalid. Applying that principle, the ITAT held such reassessment void ab initio and allowed the assessee's challenge. en-us Mon, 30 Jun 2025 00:00:00 +0530 Tue, 17 Feb 2026 19:25:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466723 Where reopening under the income-tax provisions relied exclusively on information and documents seized during a search of a third party, the statutory scheme requires invocation of the special procedure for third party seizures so that the assessing officer of the searched person records satisfaction, forwards material to the AO of the third person, and that AO records satisfaction before initiating reassessment; absent compliance, initiating proceedings under the general reopening provision circumvents these preconditions and is invalid. Applying that principle, the ITAT held such reassessment void ab initio and allowed the assessee's challenge. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466723