MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD., BILASPUR,BILASPUR vs. INCOME TAX OFFICER, WARD-1(1), BILASPUR, BILASPUR

ITA 160/RPR/2025Status: DisposedITAT Raipur18 September 2025AY 2015-16Bench: SHRI PARTHA SARATHI CHAUDHURY (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)24 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessment was based on information unearthed during a search on a third party, Section 153C was applicable, not Section 147. Therefore, the assessment proceedings initiated under Section 147 were quashed.

What were the facts?

The assessment was initiated under Section 147 based on information gathered during a search action on a third party. The assessee argued that Section 153C should have been invoked instead of Section 147, rendering the proceedings void.

What were the issues?

The primary issue was whether the assessment proceedings initiated under Section 147 were valid when the information originated from a search on a third party, suggesting Section 153C was the appropriate provision.

Which sections of the Income-tax Act were involved?

Section 147,Section 153C,Section 144B,Section 148,Section 149,Section 151,Section 68,Section 69,Section 56(2)(vii)(b),Section 50C(2),Section 69C

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI ARUN KHODPIA, AM

For Appellant: Shri Veekaas S Sharma, CA
Hearing: 07.08.2025

Per Bench: The captioned cross appeals are filed by the assessee and the revenue, emanated from the order of Commissioner of Income Tax (Appeals), National Faceless Appea

The order continues below.

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