https://www.taxtmi.com/caselaws?id=790886 Parallel reassessment under section 147 did not, by itself, invalidate section 153C proceedings; the Tribunal found no legal bar merely because both proceedings were pending at the same time, and rejected that objection. By contrast, the satisfaction note and notice under section 153C had to be recorded within a reasonable and effective time after the search-related process, and an unexplained delay of nearly four years was held to vitiate the proceedings. On that jurisdictional ground, the section 153C action was quashed and the assessee succeeded, while the challenge based on parallel proceedings failed. en-us Wed, 15 Apr 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790886 Parallel reassessment under section 147 did not, by itself, invalidate section 153C proceedings; the Tribunal found no legal bar merely because both proceedings were pending at the same time, and rejected that objection. By contrast, the satisfaction note and notice under section 153C had to be recorded within a reasonable and effective time after the search-related process, and an unexplained delay of nearly four years was held to vitiate the proceedings. On that jurisdictional ground, the section 153C action was quashed and the assessee succeeded, while the challenge based on parallel proceedings failed. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790886