No Section 147 Reopening on Third-Party Search Material: ITAT Raipur

Musaddilal Mansaram Infrastructure Pvt. Ltd. Vs ITO (ITAT Raipur) ITAT Raipur Quashes 147 Reopening – Search-Based Cases Must Proceed u/s 153C- No Independent Material Beyond Search Records – ITAT Quashes 147 Notice Assessee, engaged in real estate, filed return declaring a loss of Rs. 4.30 lakh. The return was processed u/s 143(1). Subsequently, a search u/s 132 was conducted in the case of Rashi Steel & Power Ltd. group, during which one of its Directors, Suresh Kumar Agrawal, admitted that he arranged accommodation entries through 31 shell companies.  Assessee was found to have rec...