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Reopening under Section 147 Invalid Where Search Material Triggers Section 153C
Case Law Details
- TaxGuru Citation
- 2026 taxguru.in 1498
- Case Name
- DCIT Vs Shree Sai Properties (ITAT Pune)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
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DCIT Vs Shree Sai Properties (ITAT Pune)
On-Money Addition Quashed: Reopening under Section 147 Invalid Where Search Material Triggers Section 153C
The Pune Bench of the ITAT upheld the order of the CIT(A) quashing reassessment proceedings initiated under section 147 where the entire basis for reopening was incriminating material seized during a search on a third party (Kokani Group). The Tribunal held that once seized documents allegedly relating to the assessee are found in a third-party search, the only permissible course is assessment under section 153C, and recourse to se...
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