https://www.taxtmi.com/highlights?id=99955 Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind. en-us Wed, 20 May 2026 08:31:08 +0530 Wed, 20 May 2026 08:31:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99955 Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind. Highlights Income Tax Wed, 20 May 2026 08:31:08 +0530 https://www.taxtmi.com/highlights?id=99955