HC: Reassessment proceedings u/s 147 OR u/s 153C/153A - basis for reopening assessment must be material from search.

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....The Rajasthan High Court examined the validity of reassessment proceedings u/s 147/148/148A OR u/s 153C/153A based on material/information collected during a search from another/third party. The Court held that reassessment must be conducted u/s 153C r.w.s. 153A, not u/s 148A/148. The basis for reopening the assessment was material from a search on another assessee, not new incriminating material. The petitioner argued that the assessment should have been reopened u/s 153C within the limitation period, not u/s 148/148A. The Court ruled in favor of the assessee, stating that reassessment based on search material must follow u/s 153C, not u/s 148.....