Reassessment Valid u/s 147 Despite Section 153C; ITAT Supports Penalty for Income Concealment.

The ITAT upheld the reopening of assessment under Section 147, despite the provisions of Section 153C related to search and seizure assessments. Citing PCIT vs Naveen Gupta, it concluded that Section 153C does not preclude reassessment under Section 147. The tribunal found the revenue's arguments valid, noting the Assessing Officer had tangible material and recorded reasons for reassessment, and jurisdiction could not be contested at this stage. The ITAT dismissed the assessee's claims about lack of notice and overseas detention. It also upheld a penalty under Section 271(1)(c), referencing a Supreme Court decision, due to the assessee's failure to explain income concealment. .....

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