Section 153C Prevails Over Section 148 in Third-Party Search Cases: Rajasthan HC

Gopal Prasad Gupta Vs ACIT (Rajasthan High Court)

The Rajasthan High Court considered a batch of writ petitions challenging notices issued under Section 148 of the Income-tax Act, 1961, and the consequent rejection of objections, where the basis for reopening was material seized during a search conducted on a third party (the Manihar Group). The lead case concerned Assessment Year 2014–15. The petitioner contended that since the foundation of the reassessment was incriminating material seized in a search of another person, the Department was required to proceed under the special

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