https://www.taxtmi.com/caselaws?id=796814 Reassessments based on documents seized during a search of a third party must proceed under Section 153C where the material pertains to the assessee and is relevant to determining that assessee's income. Sections 153A and 153C override the general reassessment mechanism under Sections 147 and 148 through non-obstante clauses. Consequently, Section 147 is unavailable for initiating reassessment on such search-seized material. Reassessment orders initiated under Section 147 in these circumstances lack jurisdiction and are liable to be quashed; factual additions need not be examined. en-us Wed, 05 Aug 2026 00:00:00 +0530 Tue, 11 Aug 2026 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796814 Reassessments based on documents seized during a search of a third party must proceed under Section 153C where the material pertains to the assessee and is relevant to determining that assessee's income. Sections 153A and 153C override the general reassessment mechanism under Sections 147 and 148 through non-obstante clauses. Consequently, Section 147 is unavailable for initiating reassessment on such search-seized material. Reassessment orders initiated under Section 147 in these circumstances lack jurisdiction and are liable to be quashed; factual additions need not be examined. Case-Laws Income Tax Wed, 05 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796814