#Section 147 Reassessment

When tax assessment relies on documents seized from a person other than the assessee, the Income Tax Appellate Tribunal mandates that Section 153C’s special assessment regime applies exclusively - overriding the general reassessment power under Section 147. This clarifies jurisdictional boundaries for assessing unrelated parties and prevents arbitrary reassessments based on unrelated search material.

ITAT Delhi holds that failure to pay tax under the Income Declaration Scheme 2016 within the stipulated time renders the declaration invalid, making the disclosed income taxable in the year of declaration rather than the original assessment year. This ruling underscores the strict compliance requirement for availing amnesty benefits under the scheme.