Held that a paper seized during the course of a search in the case of a group of institutions, a trust and its chairman, pertains to the assessee and it indicates a certain payment to the assessee, the AO ought to have initiated the proceedings under s. 153C against the assessee; no action under s. 147/148 could be taken against the assessee. (AY. 2011-12)
Subhash Chander Gupta v. ITO (2025) 235 TTJ 883 (Chd)(Trib)
S. 147 : Reassessment-Search-Loose papers-Satisfaction-The Assessing Officer ought to have initiated action under section 153C-Reassessment was quashed and set aside. [S. 132, 148, 153C]
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