Reassessment Valid u/s 147: No Grounds for Section 153C as No Satisfaction Note Recorded in Search.

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....Interplay between Sections 153C and 147 of the Income Tax Act, specifically whether recourse to Section 147 is available when the Assessing Officer (AO) is empowered to proceed u/s 153C. It was held that Section 153C enables the AO to assess or reassess income where incriminating assets, material, or documents are found during a search u/s 132 or requisition u/s 132A in respect of another person. However, in the present case, the jurisdictional conditions to initiate proceedings u/s 153C were not satisfied as the AO of the searched person did not record a satisfaction note and transmit relevant material to the Assessee's AO. The reassessment proceedings were initiated u/s 147 based on information received from the Investigation Wing regardi.........