Shyam Sunder Khandelwal Vs ACIT: Interplay between Sections 147/148 & 153C

Shyam Sunder Khandelwal Vs ACIT (Rajasthan High Court) The reasons supplied in case in hand for initiation of proceedings under Section 147/148 are based on the incriminating material and documents including Pen Drives seized during the search carried out of the Manihar Group and the statements recorded during proceedings. From the information received the AO noticed that the loan advanced and interest earned thereon were unaccounted. In other words the basis for initiation of Section 148 proceedings is the material seized relating to or belonging to the petitioner, during the search conducted...