Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2009-10
reassessment could have be done only u/s 153C and not u/s 147 and thus the impugned assessment order was liable to be quashed as being without Shri Neeraj Mandloi ITA No.680/Ind/2020 & C.O.No.04/Ind/2020 jurisdiction. 3.That the Ld CIT(A) failed to appreciate that section 153 C overrides section 147/148 and thus proceedings which are initiated pursuant to document seized under