Reassessment Held Void as AO Invoked Section 147 Instead of Section 153C

Advertisement V.L. Khandge Vs ITO (ITAT Pune) The ITAT Pune decided cross appeals filed by the assessee and the Revenue for Assessment Year 2006-07 arising from assessment orders passed under Section 143(3) read with Section 147 of the Income-tax Act, 1961. During the hearing, the assessee raised an additional legal ground contending that the Assessing Officer (AO) had wrongly invoked Sections 147/148 when the provisions of Section 153C were applicable. The assessee argued that the additions made in the assessment were based entirely on documents and information found during a search conduc...