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48 Tirupati Construction Co. vs. ITO
[2024] 465 ITR 611 (Raj)
A. Ys. 2016-17, 2017-18
Date of order: 21st March, 2024
Ss. 132, 147, 148, 148A, 148A(b), 153A, 153B and 153C of ITA 1961
Reassessment —Search and seizure —Assessment in search cases — Jurisdiction — Assessment of third person — Reassessment based on incriminating material and information collected prior to and post search — Permissible only u/s. 153C — Failure to assess within time limit for assessment u/s. 153C — Reassessment cannot be made u/s. 147 — Notices and orders set aside.
The assessee was a firm. The Delhi High Court allowed the writ petitions filed by the assesse against the notices for reassessment u/s. 148A and section 148 of the Income-tax Act, 1961 and held as under:
“i) Where the basis for reassessm
