Reopening under Section 147 Invalid Where Search Material Triggers Section 153C

DCIT Vs Shree Sai Properties (ITAT Pune) On-Money Addition Quashed: Reopening under Section 147 Invalid Where Search Material Triggers Section 153C The Pune Bench of the ITAT upheld the order of the CIT(A) quashing reassessment proceedings initiated under section 147 where the entire basis for reopening was incriminating material seized during a search on a third party (Kokani Group). The Tribunal held that once seized documents allegedly relating to the assessee are found in a third-party search, the only permissible course is assessment under section 153C, and recourse to section 147 is impe...