Initiation of proceedings u/s. 148 based on material found during search invalid: ITAT Delhi

Sheel Trading Company Vs ACIT (ITAT Delhi) ITAT Delhi held that based on incriminating materials unearthed during the course of search, proceedings under section 153C of the Income Tax Act needs to be initiated. Hence, initiation of proceedings u/s. 148 illegal and void ab initio. Facts- The instant appeal filed by the assessee is directed against the order dated 22.02.2024 passed by the Commissioner of Income-Tax u/s. 143(3) r.w.s. 147 of the Income-tax Act. By way of an application dated 22.10.2024 the assessee has raised additional ground of appeal mainly challenging the assumption of juris...