Reopening Invalid When Search Material Triggers Section 153C

ITO Vs Sagar Construction Company BA Gateway (ITAT Pune) Search-Based Information Triggers Section 153C, Not Reopening u/s 147 — ITAT Pune Dismisses Revenue Appeal The Pune Bench of the ITAT upheld the order of the CIT(A)/NFAC deleting additions of ₹1.61 crore (u/s 68) and ₹17.80 lakh (interest disallowance) and also accepted the assessee’s cross-objections on jurisdictional grounds, holding that reassessment under section 147 was invalid. The Tribunal held that: The entire basis of reopening was information and seized material arising from a search u/s 132 in the case of a third part...