Assessment order was quashed as search assessment should be computed u/s 153 instead of u/s 147

Karshni Metals Pvt. Ltd. Vs ITO (ITAT Delhi)

Conclusion: Since there was no failure on the part of assessee to fully and truthfully disclose material facts therefore, assessment under sections 147-148 was not valid as the specific provisions of Section 153C were deemed to take precedence over the general provisions of Section 147.

Held:  Assessee appealed against an order under Section 250 passed by CIT(A) on the issue arose from an assessment made under Sections 147/143 by the ITO. CIT(A) upheld the addition of Rs. 1,00,00,000 made by AO u

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