https://www.taxtmi.com/caselaws?id=792007 Reassessment based on search material relating to a third party must proceed under section 153C, since that special regime overrides sections 147 and 148 where seized material pertaining to another person is relied on. Reopening is also invalid where the Assessing Officer merely adopts Investigation Wing information without independent application of mind and records borrowed satisfaction instead of forming a personal belief on tangible material. In this article, the reassessment proceedings for the batch of years were quashed, and the merits of the additions were not examined. en-us Mon, 18 May 2026 00:00:00 +0530 Tue, 19 May 2026 18:01:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792007 Reassessment based on search material relating to a third party must proceed under section 153C, since that special regime overrides sections 147 and 148 where seized material pertaining to another person is relied on. Reopening is also invalid where the Assessing Officer merely adopts Investigation Wing information without independent application of mind and records borrowed satisfaction instead of forming a personal belief on tangible material. In this article, the reassessment proceedings for the batch of years were quashed, and the merits of the additions were not examined. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792007