High Court Quashes Income Tax Reopening Notices in Search-Based Assessment Cases Due to Mandatory Application of Section 153C. Assessing Officer Cannot Invoke General Reassessment Provisions Under Sections 147/148 When Material Originates from Search Under Section 132/132A, as Special Provisions Under Section 153C Override and Require Exclusive Procedural Compliance....
The judgment concerned a group of petitions challenging notices issued under Section 148 of the Income-tax Act, 1961, reopening assessments under Section 147 based on material obtained during searches...
