https://www.taxtmi.com/caselaws?id=787087 Reassessment under section 148 was invalid where additions were based on material seized from the search of another person, yet the Assessing Officer invoked the deeming fiction applicable to a search in the assessee's own case. The statutory framework required the officer to proceed under the correct clause for third-party search material, record the requisite satisfaction, and obtain prior approval before issuing notice. Because those jurisdictional steps were not followed and the recorded reasons did not meet the reopening conditions, the notice lacked legal validity and the resulting assessment was vitiated. en-us Wed, 18 Feb 2026 00:00:00 +0530 Thu, 26 Feb 2026 07:35:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787087 Reassessment under section 148 was invalid where additions were based on material seized from the search of another person, yet the Assessing Officer invoked the deeming fiction applicable to a search in the assessee's own case. The statutory framework required the officer to proceed under the correct clause for third-party search material, record the requisite satisfaction, and obtain prior approval before issuing notice. Because those jurisdictional steps were not followed and the recorded reasons did not meet the reopening conditions, the notice lacked legal validity and the resulting assessment was vitiated. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787087