ITAT Quashes Assessment for Failure to Follow Section 148 Procedure on Third-Party Seized Documents

Ramesh Zalpuri Vs DCIT/ACIT (ITAT Delhi) Summary: The Income Tax Appellate Tribunal (ITAT) Delhi quashed assessments framed under Section 143(3) against the assessees for AY 2022-23 after holding that additions based on documents seized from a third party during a search operation could not be sustained without following the mandatory reassessment procedure under Sections 147/148 of the Income Tax Act. The case arose from a search conducted on the U-Flex/Montage Group, where certain documents and electronic records allegedly showed that employees received cash salary over and above regular sal...