Where reopening proceedings were initiated on the basis of information and material gathered pursuant to a search conducted under section 132 in the case of a third party, the very foundation of the reassessment arose from incriminating material discovered during the search. In such circumstances, the statutory scheme mandates that assessment must necessarily be undertaken under sections 153A/153C, which contain a non-obstante clause overriding sections 147 and 148. The provisions relating to reassessment under section 147 operate in a distinct field and can be invoked only where income escaping assessment is not based on search proceedings. Once the Revenue seeks to rely upon material emanating from a search action, resort to section 147 is impermissible and would result in overlapping of mutually exclusive statutory regimes. Following PCIT v. Abhisar Buildwell (P.) Ltd. (2023) 332 CTR 729 (SC) and concurring with decisions of the Rajasthan and Karnataka High Courts, it was held that since the reopening was founded entirely on search material, proceedings ought to have been initiated under section 153C read with section 153A and not under section 147. Accordingly, the notice issued under section 147 and all consequential proceedings were quashed as being without jurisdiction and bad in law. (AY. 2012-13).