COMMON JUDGMENT

T.S.Sivagnanam,J These appeals are directed against the common order passed in W.P.Nos.481 and 482 of 2020 dated 01.07.2021, whereby the writ petitions filed by the appellant were dismissed.

2.The orders impugned in the writ petitions were the proceedings initiated by the respondent under Section 147/148 of the Income Tax Act ['the Act' for brevity] for the assessment years 2016-17 and 2017-18. The validity of the reopening proceedings was questioned by the appellant on several grounds. Firstly, by contending that the respondent has no jurisdiction to issue notice under Section 148 of the Act and propose to make an assessment under Section 143(3) r/w. 147 of the Act although the materials relied upon were obtained during a search under Section 132 of the Act of another party at New Delhi. Further, it was contended that where the material relied upon was obtained in the course of search of another party, the proceedings of the appellant can be initiated only under Section 153C of the Act and no re-assessment under Section 147 of the Act can be resorted to. Therefore, it was contended that the re-assessment proposed under Section 147 of the Act is without jurisdiction.