Assessment Proceedings should be conducted u/s 153C instead of Section 147 when material is found on Third-Party Premises: ITAT

The ITAT ruled that assessment proceedings should be conducted under Section 153C instead of Section 147 when material relevant to an assessee is found on third-party premises. This decision came in a case where the tax authorities attempted to reassess an individual’s income based on documents found during a search on another party. The tribunal held that the correct procedure was to initiate proceedings under Section 153C, which deals with such scenarios, rather than the general reassessment provision under Section 147.