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INCOME TAX APPELLATE TRIBUNAL (PUNE BENCH)
MANISH BORAD, Accountant Member, ASTHA CHANDRA, Judicial Member
Ajay Abasaheb Khamkar – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. factual background of search and seized material (Para 1 , 6 , 7) |
| 2. assessee's grounds challenging reassessment validity (Para 2) |
| 3. parties' arguments on s.153c vs s.148 applicability (Para 3 , 4) |
| 4. section 153c mandatory for pre-2021 third-party search material (Para 5 , 8 , 9 , 10) |
| 5. appeal allowed; reassessment quashed for lack of jurisdiction (Para 11 , 12) |
ORDER
PER DR. MANISH BORAD, ACCOUNTANT MEMBER :
The captioned appeal at the instance of assessee pertaining to A.Y.2019-20 is directed against the order dated 27.10.2025 framed by National Faceless Appeal Centre, Delhi arising out of Assessment Order dated 27.12.2024 passed u/s. 147 r.w.s.144B of the (in short ‘the Act’).
2. Assessee has raised following grounds of appeal :
“1]. The learned CIT(A) erred in upholding the validity of notice u/s 148 without appreciating that the reasst. proceedings in the instant case were initiated on the basis of certain documents allegedly relating to the assessee which were found in the course of search action conducted on Mr. Rajendra Abhale on 20.02.2019 i.e. prior to 01.04.2021 and hence, action, if any, ought to have been initiated under the special provisions of section
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