Recourse u/s. 147 not prohibited if conditions of reopening u/s. 153C not satisfied

PCIT Vs Agroha Fincap Ltd. (Delhi High Court) Delhi High Court held that non-satisfaction of conditions for reopening assessment u/s. 153C of the Income Tax Act doesn’t prohibit AO from taking recourse u/s. 147. Thus, reopening u/s. 147 based on information from investigation wing justified. Facts- The Assessing Officer had issued the notice u/s. 148 of the Act. The assessment proceedings culminated in an assessment order passed u/s. 147 of the Act, whereby AO made an addition of ₹25,45,000/- comprising of  ₹25,00,000/- u/s. 68 of the Act and ₹45,000/- u/s. 69C of the Act. CIT(A) reje...