AMIT SINGLA HUF,DELHI vs. 88, SECOND FLOOR, GAGAN VIHAR EXTENSION, KRISHNA NAGAR, EAST DELHI, DELHI 110051, DELHI
What did the Tribunal hold?
The Tribunal held that the assessments framed under section 153C were not sustainable due to the absence of a valid satisfaction note. The satisfaction note lacked discussion on whether the seized material belonged to or pertained to the assessees.
What were the facts?
The appeals concerned assessment year 2017-18 and arose from proceedings under section 153C of the Income-tax Act. The assessees challenged the validity of these proceedings.
What were the issues?
The key issue was the validity of section 153C proceedings due to a defective satisfaction note from the Assessing Officer.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI
BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 882/DEL/2026 Assessment Year: 2017-18 Amit Singla, Vs Deputy Commissioner of 88, Second Floor, Gagan Vihar Income Tax- Central Circle Extension, 28, Delhi-51 Jhandewalan Extension, New Delhi- 55 (APPELLANT) (RESPONDENT) PAN No. BATPS0949G
ITA No. 883/DEL/2026 Assessment Year: 2017-18 Amit Singla HUF, Vs Deputy Commissioner of 88, Second Floor, Gagan Vihar Income Tax- Central Circle Extension, 28, Delhi-51 Jhandewalan Extension, New Delhi- 55 (APPELLANT) (RESPONDENT) PAN No. AAQHA4516F Assessee by: Sh. Anmol Sinha, Adv. Revenue by : Sh. Zafarul Haque Tanweer, CIT DR
Date of Hearing: 11.08.2026 Date of Pronouncement: 11.08.2026 ORDER PER SATBEER SINGH GODARA, JM: These twin assessees’ as many appeals ITA Nos. 882 & 883/Del/2026; both for assessment year 2017-18, arise against Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Delhi-25’s orders both dated
18.11.2025, passed in DINs & order nos. ITBA/APL/S/250/2025- 26/1082735937(1) & ITBA/APL/S/250/2025-26/1082737737(1), involving proceedings under section 153C of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); respectively.
Heard both the parties. Case files perused.
It emerges at the outset that both these assessees/appellants canvass their first and foremost identical legal ground challenging validity of the impugned section 153C proceedings initiated in their respective cases for want of a valid satisfaction note thereunder. That being the case, learned counsel places on record the Assessing Officer’s satisfaction note(s) dated 24.06.2022 initiating the impugned proceedings wherein there is not even an iota of discussion as to whether the corresponding seized material in fact “belonged to” or “pertained to” or “related to” therein; as prescribed in clause (a) and (b) to section 153C of the Act. This clinching factual position has gone unrebutted from the Revenue side. We accordingly quote Super Malls (P.) Ltd. vs. Principal Commissioner of Income Tax, 8 New Delhi [2020] 115 taxmann.com 105 (SC) that these twin assessees’ impugned as many assessments framed u/s 153C of the Act are not liable to be sustained for want of a valid satisfaction recorded thereunder. The same are hereby quashed in very terms therefore.
All other remaining pleadings between the parties on merits stand rendered academic.
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These twin assessees’ appeal ITA Nos. 882 & 883/Del/2026 are allowed in above terms. A copy of this common order be placed in the respective case files.
Order pronounced in the open court on 11.08.2026 .
Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 13.08.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR
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More judgments on Section 153C
- Neepaben Sunnybhai Motwani, Rajkot vs Income Tax Officer, RajkotITA 875/RJT/2026[2021-22]Status: Disposed19 Oct 2026AY 2021-22
- Neepaben Sunnybhai Motwani, Rajkot vs The Income Tax Officer, RajkotITA 874/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Venish Vinodray Lalani, Rajkot vs Income Tax Officer, MorbiITA 197/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Ajay Singh, Kota vs DCIT, Central Circle, KotaITA 495/JPR/2026[2016-17]Status: Disposed13 Oct 2026AY 2016-17
- Dineshkumar Chhaganlal Manavadaria, Junagadh vs ITO Ward 1, JunagadhITA 837/RJT/2025[2020-21]Status: Disposed9 Oct 2026AY 2020-21
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