If conditions for reopening of the assessment under Section 153C is not satisfied, recourse to Section 147 is not precluded: Delhi HC
Hon’ble Delhi HC holds that in the event the conditions for reopening of the assessment under Section 153C of the Act are not satisfied, recourse to Section 147 of the Act based on information as received, was not precluded.
The court observed that the ITAT had erroneously held that proceedings under Section 147/148 of the Act were without jurisdiction as only proceedings under Section 153C of the Act could be initiated, as information received was based on a search and seizure operation.
The copy of the order is as under:
