ITAT Quashes Reassessment as AO Invoked Section 147 Instead of Section 153C

Zubin Paul Driver Vs ACIT (ITAT Mumbai) Section 147 Assessment Held Invalid Because Seized Third-Party Material Required Proceedings Under Section 153C; Assessment Declared Invalid Because Search Material Triggered Section 153C, Not Section 147 The assessee appealed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), dated 09.10.2025 for Assessment Year 2010-11, arising from an assessment made under Section 143(3) read with Section 147 of the Income Tax Act. The appeal challenged the reopening of assessment under Section 147, the validity of ...