https://www.taxtmi.com/caselaws?id=790038 In a third-party search, incriminating material relatable to another person triggers the special assessment procedure under section 153C of the Income-tax Act, rather than the regular reassessment route under sections 147 and 148. The Tribunal relied on the binding High Court view that, where seized documents or digital material found in search proceedings of one group are connected to a different person, the reassessment initiated under section 148 is unsustainable for that material. The appellate order quashing the notice and deleting the additions was upheld, and the revenue's challenge failed on the jurisdictional issue. en-us Mon, 23 Mar 2026 00:00:00 +0530 Sat, 18 Apr 2026 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790038 In a third-party search, incriminating material relatable to another person triggers the special assessment procedure under section 153C of the Income-tax Act, rather than the regular reassessment route under sections 147 and 148. The Tribunal relied on the binding High Court view that, where seized documents or digital material found in search proceedings of one group are connected to a different person, the reassessment initiated under section 148 is unsustainable for that material. The appellate order quashing the notice and deleting the additions was upheld, and the revenue's challenge failed on the jurisdictional issue. Case-Laws Income Tax Mon, 23 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790038