https://www.taxtmi.com/caselaws?id=798761 Third-party search material relating to a person other than the searched person falls within the distinct assessment framework under Sections 153A and 153C. Where seized electronic data, statements and transaction details form the sole basis for proposed action, reassessment under Sections 148A and 148 is unavailable. Subsequent analysis or corroboration does not change the search-derived source of the material or permit use of the general reassessment mechanism. Invoking extended limitation or obtaining approval cannot cure an invalid assumption of jurisdiction. Reassessment proceedings initiated on that basis are without jurisdiction and invalid. en-us Thu, 03 Sep 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:30:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798761 Third-party search material relating to a person other than the searched person falls within the distinct assessment framework under Sections 153A and 153C. Where seized electronic data, statements and transaction details form the sole basis for proposed action, reassessment under Sections 148A and 148 is unavailable. Subsequent analysis or corroboration does not change the search-derived source of the material or permit use of the general reassessment mechanism. Invoking extended limitation or obtaining approval cannot cure an invalid assumption of jurisdiction. Reassessment proceedings initiated on that basis are without jurisdiction and invalid. Case-Laws Income Tax Thu, 03 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798761