Incriminating Material found during search of third party: Section 153C vs. 147

Narendra Kumar Vs ITO (ITAT Delhi)

ITAT Delhi held that addition based on incriminating material found during the search carried out of ‘some other person’ i.e. third person/ party and assessing the same by invoking provision of section 147 instead of section 153C is unsustainable.

Facts- the assessee filed return declaring income of Rs. 9,05,470/- for Assessment Year 2012-13. The case was taken up for scrutiny and the assessment u/s 148/147 of the Act was completed on

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