Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

Viru Textile Mills Pvt. Ltd. Vs ITO (ITAT Ahmedabad) Where reopening is based solely on incriminating material seized during search on a third party, the Revenue must proceed under section 153C and cannot bypass the special search assessment code by invoking sections 147/148. In Viru Textile Mills Pvt. Ltd. Vs ITO, the ITAT Ahmedabad considered reassessment proceedings initiated under Sections 147/148 for AYs 2016-17 and 2017-18 based on material seized during a search conducted on the Sanjay Tibrewal Group. The assessee challenged the reopening on multiple legal and factual grounds, including...