GAUTAM SEHGAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

ITA 2705/DEL/2026Status: DisposedITAT Delhi09 September 2026AY 2019-2014 pages
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What were the facts?

During a search operation, incriminating documents were found suggesting cash payments totaling Rs. 1.70 Crores were made to the assessee for a property purchase. The Assessing Officer initiated proceedings under Section 153C based on these documents and statements.

What did the Tribunal hold?

The Tribunal held that the assessment proceedings were vitiated due to the Assessing Officer's failure to provide the assessee with an adequate opportunity to cross-examine key witnesses and examine the incriminating material. A consolidated satisfaction note covering multiple assessment years, some of which lacked incriminating material, was also found to be defective.

What were the issues?

Whether the assessment proceedings initiated under Section 153C were valid without providing adequate cross-examination opportunities and whether a consolidated satisfaction note covering multiple assessment years was legally sustainable.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153A,Section 143(3),Section 271D,Section 132,Section 131,Section 144(1)(a),Section 144(1)(b),Section 139(1),Section 127(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES, NEW DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

Pronounced: 09.09.2026

PERSHRI ANUBHAV SHARMA, JUDICIAL MEMBER: These appeals preferred by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-26, Delhi (hereinafter referred to as the First Appellate Authority or ‘the ld. FAA’ for short) in appeals filed

ITA 2705& 2726/DEL/2026 GAUTAM SEHGAL

before him against the orders of the ld. Assessing Officer (hereinafter referred to as the Ld. AO, for short) passed u/s 153C r.w.s 153A 143(3)

The order continues below.

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