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    <title>Reopening assessment invalid where notice under section 147 issued instead of 153C on third party search basis; reassessment quashed.</title>
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    <description>Reopening of assessment initiated on basis of a third party search was invalid because the assessing officer issued a notice under the general reassessment provision instead of the provision applicable to material seized in a third party search; accordingly the reassessment notice was quashed and the assessee&#039;s ground on that point allowed. The appellate authority&#039;s deletion of the addition under unexplained cash loan/interest was noted. Objection that the assessment order was cryptic or passed hastily was rejected: delay by the assessee in filing return and seeking reasons, and limitation pressures, meant the gap before final order did not invalidate the assessment process.</description>
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    <pubDate>Fri, 27 Feb 2026 13:13:42 +0530</pubDate>
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      <title>Reopening assessment invalid where notice under section 147 issued instead of 153C on third party search basis; reassessment quashed.</title>
      <link>https://www.taxtmi.com/highlights?id=97247</link>
      <description>Reopening of assessment initiated on basis of a third party search was invalid because the assessing officer issued a notice under the general reassessment provision instead of the provision applicable to material seized in a third party search; accordingly the reassessment notice was quashed and the assessee&#039;s ground on that point allowed. The appellate authority&#039;s deletion of the addition under unexplained cash loan/interest was noted. Objection that the assessment order was cryptic or passed hastily was rejected: delay by the assessee in filing return and seeking reasons, and limitation pressures, meant the gap before final order did not invalidate the assessment process.</description>
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      <pubDate>Fri, 27 Feb 2026 13:13:42 +0530</pubDate>
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