Shailesh S. Patel v. ITO
97 Taxmann.com 570Income Tax Appellate Tribunal2018#3297 most cited
What is Shailesh S. Patel v. ITO authority for?
Section 147 can be invoked to tax income found during a search in the hands of a person other than the person searched, even without invoking Section 153C, although the latter provides specific jurisdiction for search assessments.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2019 to 2025.
Also referred to as
Shailesh S. Patel v. ITO · Section 147 · Section 153C · search proceedings · incriminating material · person other than searched person · reassessment · assessment procedure