https://www.taxtmi.com/caselaws?id=469576 Reopening under section 147 was impermissible where the recorded reasons showed reliance on seized material from a search conducted in a third party's case. On those facts, section 153C was the specific jurisdictional mechanism for assessment of a person other than the searched person, and the use of section 147 could not substitute it. The issue was treated as jurisdictional and therefore capable of being raised at any stage. Applying binding jurisdictional precedent and coordinate bench authority, the assessment framed under section 143(3) read with section 147 was held invalid and bad in law. en-us Mon, 30 Mar 2026 00:00:00 +0530 Mon, 22 Jun 2026 19:00:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469576 Reopening under section 147 was impermissible where the recorded reasons showed reliance on seized material from a search conducted in a third party's case. On those facts, section 153C was the specific jurisdictional mechanism for assessment of a person other than the searched person, and the use of section 147 could not substitute it. The issue was treated as jurisdictional and therefore capable of being raised at any stage. Applying binding jurisdictional precedent and coordinate bench authority, the assessment framed under section 143(3) read with section 147 was held invalid and bad in law. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469576