https://www.taxtmi.com/caselaws?id=790043 Search-derived material relating to another person must be dealt with under the special search-assessment framework of sections 153A and 153C, which requires recording satisfaction before action is taken against the other person. Reassessment under sections 147/148 cannot be used to bypass that special mechanism where the reopening is founded exclusively on material unearthed in search proceedings. Only independent external material can justify reassessment under sections 147/148 in such circumstances. On that basis, the reassessment was held to be without jurisdiction and set aside. en-us Tue, 24 Mar 2026 00:00:00 +0530 Sat, 18 Apr 2026 08:22:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790043 Search-derived material relating to another person must be dealt with under the special search-assessment framework of sections 153A and 153C, which requires recording satisfaction before action is taken against the other person. Reassessment under sections 147/148 cannot be used to bypass that special mechanism where the reopening is founded exclusively on material unearthed in search proceedings. Only independent external material can justify reassessment under sections 147/148 in such circumstances. On that basis, the reassessment was held to be without jurisdiction and set aside. Case-Laws Income Tax Tue, 24 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790043