Case Law Analysis
|Bombay High Court
Section 153C ITA | Assessment Based on Third-Party Search Material Must Follow Special Regime, Not Section 147 Reassessment : ITAT Mumbai
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.