Action u/s. 147 not justified when material found during search of another person is sole basis for reopening

Parshwa Investment Vs DCIT (ITAT Mumbai) ITAT Mumbai held that where the entire foundation of reopening solely based on material found during the search of another person, the appropriate course of action is to proceed under Section 153C, and not under Section 147. Accordingly, reassessment proceedings u/s. 147 quashed. Facts- In the course of reassessment, the Assessing Officer noted that the assessee had received unsecured loans aggregating ₹71,52,27,967/- from four entities and concluded, relying upon the search material and statements, that a sum of ₹7,15,22,797/- constituted unexplai...